ML17298B587

Requests Schedular Exemption from 840927 Commitment to Use Backup Sampling to Meet Requirements of NUREG-0737,Item II.B.3 Be Granted,Prior to Exceeding 5% Power,Due to Mods Required on post-accident Sampling Sys.Action Plan Encl

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)

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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 CODE: B001D>>COPIES -RECEIVED:LTR~ "

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1 NRR/OHFS/PSRB 1 1 NRR/DL/SSPB 1 0 NRR/DS I/AEB 26 1 1 NRR/DSI/ASB 1 1 NRR/DSI/CPS 10 1 1 NRR/DS I/CSB 09 1 1 NRR/DSI/ICSB 16" 1 1 NRR/DSI'/METB 12'B 1 1 NRR/DS I/PSB 19 1 1 22 1 1 NRR/DS I/RSB 1 1 G 0Q 1 1 RGN5 3 3 RM/DDAMI/MIB 0 EXTERNAL: BNL (AMDTS ONlY) 1- 1 DMB/DSS (AMDTS) 1 1 FEMA REP DIV 39 1 1 LPDR 03 1 1 NRC PDR 1 1 NSIC 05 1 1 02'TIS 1 i PNL GRUEL'iR 1 1 "TOTAL'UMBER OF 'COPIES'EQUIRED: LTTR 50 ENCL 46

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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.

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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, APS

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Vice President Jr.

Nuclear Production ANPP Project Director EEVB/NLH/MAJ/JBC/RLJ/jle Attachment cc: A. C. Gehr 'with attachments)

E. A. Licitra (with attachments)

R. P. Zimmerman (with attachments)

J. [Gng (with attachments)

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ANPP-31333 STATE OP ARIZONA )

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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 1984.

I n Notary Public My Comm%'ssion:Expires:

F M Commlsslon "IresA rll6 1987

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Mr. George W. Knighton Post Accident Sampling System Page 3 ANPP-31333 bcc:

T. G. Woods 1910 (all with attachments)

D. B. Karner 4060 J. R. Bynum 6125 J. R; Kirby 6249

0. J. Zeringue 6125 J. M. Allen 6130 J. D. Houchen Tr ~ 25 N. L. Helman 4053 A. C. Rogers 4056 R. W. Page 6010 J. B. Cederquist 6080 S. R. Frost 4080 R. A. Ferguson 6425 R. L. Jenkins 6238 W. F Quinn 4057 T. F Quan 4057 K. E. Jones 4057 J. W. Rowland 4053 M. J. Winsor 6254 D. R. Canady 6177 K. W. Gross 6088 K. M. Smith 6080 E. A. Cole 6080 J. A. Scott 6281 T. J. Warren, . 6431

'R. G. Johnson 6544 P. M. Egebrecht 6238 LCTS Coordinator 4057, W. H. Wilson, BPC/Downey S. Shepherd BPC/Downey C. Ferguson BPC/Downey M. Barnowski BgS/Dotpey, 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.

reviewed the progress, found Vendor progress to be unsatisfactory

'e have 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.

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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.

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Page 1 of 1 TABLE A NOR%6 PASS INLINE INSTRUMENTS POST MODIFICATION ION SPECIES SENSITIVITY ACCURACY "'ALIBRATION CAPABILITY LIQUID SAMPLE 1-13 2, 12 +.5pH 74CH-9ZZ90 Note 1 Note 12 Note 1 Rev.1 Conductivity 0-10~7 mhos/cm +2X10~mhos/cm 1000~ mhos/cm 74CH-9ZZ90 Note 3 Note 12 4'o4 Rev. 1 Dissolved Oxygen 0-20 ppm ~ 2 ppm ppm 74CH-9ZZ90 Note 2 Note 12 Rev. 1 Chlor ide Ion 0-20 ppm ~ 1 ppm ++05 ppm 74CH-9ZZ90 Note 3 Note 12 P Zlppm; +55 Rev. 1 of Reading Q)l ppm Total Dissolved Gas 100-2000 cc/kg 100 cc/kg 74CH9ZZ90 Note 2 Note 12 (and Dissolved Rev. 1 Hydrogen)

Radio-Isotope 10 QCi/cc 10 W Ci/cc Factor of 2 7401-9ZZ90 Note 4 Note 12 (liquid) to 10 Ci/cc Rev. 1 0-6000 ppm 100 ppm +5>> of Reading 74CH-9ZZ90 Note 2 Note 12

+5p Rev. 1 Gaseous Hydrogen 1$ H +.75$ H2 74CH-9ZZ90 Note 3 Note 12 (also used for off- (in 52) Tin N2) Rev. 1 gas analysis) 1502 +.75$ 02 74CH-9ZZ90 Note 3 Note 12 Rev. 1 Radio-Isotope 10 3~ ((i/cc 10 ~Ci/cc Factor of 2 74CH-9ZZ90 Note 4 Note 12 (Gaseous) to 10 Ci/cc Rev. 1 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)

CURREt1T IOiV SPECIES SENSITIVITY PROCEDURE CALIBRATION CAPABILITY LIQUID SAMPLE 1-13 +0.3 pH 74%-9ZZ35 N/A Ccmplete, Rev. 2 System EPIP-27 Operable Note 6, 9 Dissolved Oxygen 20 to 2000 20 cc/kg +104 of Reading 74CH-9ZZ65 N/A Complete, cc/kg EPIP-27 System Operable Note 6, 11 Dissolved Hydrogen 10 to 10cc/kg +105 of Reading 74CH-9ZZ65 N/A Canplete, 2000 cc/kg EPIP-27 System Operable Note 6, 11 Chloride Ion Ion Cheat- 0.02 ppm +0.05 ppm 6 ( 74CH-9ZZ72 Rev. 1 Note 3 Complete, System ograph

.02-20 ppm

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+104 6 ) 0.5ppm EPIP-27 Operable Note 8 Autotitra- 2 ppm +5/ of Reading 74CH-9ZZ06 Note 3 Canplete,

~ metric Rev.2 System 2 - 6000ppm 74%-9ZZ72 Operable EPIP-27 Note 10 Total Dissolved 50 to 2000 50 cc/kg + 20$ 74CH-9XC34: N/A Complete Gas cc/kg Note 22 Rev. 0 System EPIP-27 Operable Note 6, 11

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Page 2 of 2 TABLE B PASS BACKUP GRAB $ &PLE, (HIGH RADIATION FIELD)

(Continuation)

CURRENT ION SPECIES RANGE SENSITIVITY ACCURACY PROCEDURE CALIBRATION CAPABILITY Radio-Isotope 3 decades Note 5, 7 +5) 74CH-9ZZ63 Note 4 Complete, Liquid) above MDA Rev. 1 System 74CH-9ZZ48 Operable Rev. 1 Note 2,5,7 Gaseous Hydrogen Gas Chromato- 100ppm +255 of Reading 74CH-9ZZ65 Note 3 Complete, graph 100 ppm- Rev. 1 System 10% Operable Note 2,6, 11, Gaseous Oxygen Gas Chromato- 1000ppm +255 of Reading 74CH-9ZZ65 Note 3 Ccmplete, graph 1000 Rev. 1 System ppm to 10$ EPIP-27 Operable Note 2,6, 11 Radio-Isotope 3 Decades Note 5 +5) 74CH-9ZZ63 Note 4 Complete, (Gaseous) above MDA Rev. 1 System 74CH-9ZZ48 Operable Rev. 1 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 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.

Note 6 Undiluted Sample Only.

Note 7 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 the specific methodology. 'escribes 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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