ML20084B753
| ML20084B753 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/08/1984 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20084B699 | List: |
| References | |
| 5211-84-2068, NUDOCS 8404260316 | |
| Download: ML20084B753 (12) | |
Text
b GPU Nuclear Corporation Nuclear
- ,ome 8:,v8o s
Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
5211-84-2068 March 8, 1984 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Inspection Report 84-03
/ /.
Inspection Report 84-03, dated February 23, 1984 dealt with Post Accident Sampling and Monitoring. On February 23, 1984, GPUN met with NRC to discuss the findings of IR-84-03 and committed to provide within two weeks a list of those actions which are planned along with commitment dates targeted for completion of each item. describes each of our commitments and provides a target date for completion. Attachment 2 provides responses for several of these items.
Sincerely,
. D.
u ill Director, TMI-l HDH:RK/kls attachments cc:
R. Conte khkO G
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
m m Attachment i Page I POST ACCIDENT SAWt. LNG AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR GPUN Targeted item Action Completion No.
Inspection Report item No.
G'UN Action Date (Note 1) 84-03-01 RCS SAW1. LNG l.a Provide the capability to obtain an RCS 1.a.1 Revise the EPIP Involved in taking the Post Accident 04/01/84 sample under all accident conditions and RCS sample (1004.15) to include, as an option, the modes of operation, taking of a sample from the Pressurizer rather than the RCS cold leg. (Exposure would be the same as taking a loop sample.)
1.a.2 Describe GPUN position on sampling at low pressure.
Complete.
See 1.a.3 Complete modification of post accident sampling 10/01/84 system to tie In decay heat sample lines with the shleided reactor coolant sample line in the nuclear sampling room, l.a.4 Revise procedure to include taking a post accident 04/05/84 sample from the dscay heat system in the present system configuration. Cautions are to be included to define the need to determine plant conditions and radiation levels prior to obtaining authorization from the Emergency Director to obtain a Decay Heat sample.
1.a.5 Revise TDR 494 to include additional exposure 05/01/84' considerations for taking a decay heat sample after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the present system configuration.
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Attachment i Page 3 POST ACCIDENT SMPLING N3 MONITORING (IR 84-03)
OUTSTANDING ITEMS IR OPUN Targeted l
Item Action Completion No.
Inspection Report item No.
(PUN Action Date Obte 1) l 84-03-03 OTER l
I 3.a Analyze W potential for CA-RV5 to lift 3.a.1 Provide a response to item 3.a.
Complete.
l at 125# and vent coolant to the Aux. Bldg.
Soo sump during flushing and purgirg of W IInes or valve failure.
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3.b Determine the resultant pressure once the 3.b.I Provide a response to Item 3.b.
- Complete, i
dissolved gases are stripped from the See solution in order to accurately determine the activity concentration.
3.c Establish a formal preventive maintenance 3.c.I Describe formal preventive maintenance and survell-05/01/84*
and surveillance program for the CAS lance programs for the Containment Atmosphere system.
Sampling System, and provide a schedule for implementation.
l 3.c.2 incorporate procedural changes required to implement 05/01/84 the program described In 3.c l.
3.d Address W dose received by personnel 3.d.1 Develop a revised process for collecting and trans-05/01/84 transporting W sample to the counting porting the sample using a portable pig, procedur-room.
alize the process, and perfom time and motion studies. (See 3.e.1 and 4.2.1) r 3.d.2 Revise.JR 529 to include the dose received by 06/01/84' j
personnel transporting the sample to the counting room (See 4.2.1).
Consider dose contribution from l
hydrogen recombiners.
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l 3.e Address the possibility of high airborne 3.e.1 Revise the procedure to require a respirator to 05/01/84 radioactivity while coIIecting the CAS be worn.
and the need to weer a respirator.
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Attachment i Page 2 POST ACCIDENT SAPPLING ADO MONITORING (lR 84-03)
OUTSTAPOING ITEMS 33 N
Targeted Item Action Completion No.
Inspection Report Item No.
GPUN Action Date (Note 1) 84-03-02 CAS 2.a pbdify CAS to permit sampling af ter 2.a.I Rawlse procedures to enable override of containment 05/01/84 co.itainment isolation. Provide tempera-Isolation above 30#.
ture and pressure Indications at tho gas sample bomb. Develop procedures to 2.a.2 Review the design of the Containment Atmosphere 05/01/84' quantify the sample including temperature Sampling System and provide a schedule for completion and pressure corrections.
of any modifications. Address the need for:
- 1) Additional heat tracing and/or Insulation
- 2) Elimination of the flowmeter
- 3) Elevation of the sample bomb
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- 4) Shleiding the sample bomb 2.a.3 Provide a writeup to describe operation of the 05/01/84*
Containment Atmosphere Sampling System Including any modifications.
l 2.a.4 Pbdify procedures to quantify the sample including 06/01/84 I
temperature and pressure corrections.
2.b Evaluate sample representativeness In 2.b.I Describe the design of the Containment Atmosphere 05/01/84' regard to possible condensation and Iodine Sampling System to obtain a representative sample l
plateout In the gas sample bomb.
In regard to possible condensation and Iodine l
plateout in the gas sample bomb.
2.c Perform error analysis to estimate the 2.c.I Describe sample transfers, perform error analysis 05/0l/84*
sample losses attributed to sample and describe acceptability of the Containment transfers called for In the procedures.
Atmosphere Sampling System equipment.
2.c.2 Investigate the need for special precautions which 05/01/84 might need to be taken to prevent unnecessary failure of the syringe used in obtaining the containment atmosphere seiple and Incorporate any necessary procedural changes.
047Ik l
Attachment i Page 4 POST ACCIDENT SMPLitG Ate MONITORitG (IR 84-031 00TSTAtoltG ITEMS IR
&UN Targeted Item Action Completion Pb.
Inspection Report item ib.
TUN Action Date (tbte 1) 3.f Containment Hydrogen Analyzers have not 3.f.I Provide a response to item 3.f.
- Complete, been tested or calibrated and operational See procedures have not been written.
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3.g tb procedural provisions for coIIecting 3.g.I Provide a response to item 3.g.
Conp lete, grab sample for Hydrogen analysis.
See 84-03-04 SHIELDitG 4.1 Revise shielding study (RCS sampling) 4.1.a Perform dose rate cales and revise TDR 494 to 05/0l/84*
to include the following contributors:
Include contributors listed in 4.1 for as-bullt a - Sink drain trap and drain line.
configuration and specify source terms, b - Undiluted coolant In the sink.
c - Scattered radiation.
4.l.b Provide a response to address measures which are Complete.
d - Unshielded auxillary lines.
being taken to minimize the dose contributions See e - Residual contamination during listed In item 4.1.
subsequent sample attempts.
f - Airborne radioactivity originating 4.1.c Revise procedure to verify In-flow of air into the 04/01/84 from sink.
sample hood prior to Initiation of RCS sample flow In order to minimize alrborne radioactivity originating from the sink. The determination of air flow will be based on visually checking that ribbons attached to the bott(n of the hood door are pulled into the I.ood.
4.l.d Revise EPIP 1004.15 to require Radiological Assessment 04/01/84 Coordinator and Emergency Director concurrence prior to initiating flow through auxillary systems which might Introduce high activity water through unshielded auxillary IInes located in the chemistry lab / sample sink area.
4.1.e Provide temporary shleiding for the sample sink drain 06/01/84 IIne and revise procedure to verify shielding is In place prior to Initiation of RCS sample flow.
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Attachment i Page 5 POST ACCIDENT SMFLIPG AfD MONITORING (IR 84-03)
OUTSTANDING ITEMS
]
IR CPUN Targeted Isen Action Completion No.
Inspection Report Item M).
(PUN Action Date (Note 1) k 4.2 Conduct a shielding study on the as-built 4.2.8 Revision to TDR 529 described in 3.d.2 will include 06/0l/84*
system for collecting and transporting shleiding studles for collecting and transporting the CAS.
the Containment Atmosphere Sample (see 3.d.2).
84-03-05 ANALYTICAL CAPABILITY l
5.a Develop procedures for use of 5.a.1 Provide an Interim response to item 5.a.
Comlete. See fluoroborate probe and pH mintprobe.
5.a.2 Complete the necessary procedural modifications for 04/01/84 performing the Chlorlde, Boron, and pH analysis using permanent equipment dedicated for use at TMI-l.
(Lower minimum range for Boron analysts Is 500 ppe.)
5.a.3 Resolve the problem regarding fluoroborate analysis 07/01/84
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for Baron concentrations below 500 ppm or Justify a lower minimum range for Boron analysis of 500 ppe.
5.b Provide the results of demonstration of 5.b.I Perforia demonstrations onsite using TMI-I procedures 04/01/84 chemical analysis capability for to confirm the results transmitted to PRR on 2/29/84 Chloride, Baron, and pH using the In preparation for Inspector followup demonstrations.
Intended Instrumentation and procedures.
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5.c Revise procedures to address analysis of 5.c.I Provide an Interim response to 5.c.
Complete.
fission gases stripped from the RCS sample See for determining gross activity.
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l 5.c.2 Provide a complete response to 5.c.
06/01/84*
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5.d Provide shielding for the Ion 5.d.1
. Provide a respor.se to 5d.
Complete.
chromatograph.
See 037I.k I
Attachment l l
Pcge 6 l
POST ACCIDENT SN1PL!NG AND MONITOR 1NG (lR 84-03)
OUTSTANDING ITEMS 33 CPUN Targeted item Action Completion No.
Inspection Report item tb.
G)UN Action Date (Note 1) 84-03-06 NOBLE GAS EFFLUENT MONITOR 0.a Provide conversion factors from CPM to 6.a.I Describe the modifications to offsIte dose calcula-Complete.
mci /cc for monitor readouts.
tion software which were incomplete at the time of See s
inspection 84-03.
6.a.2 Complete the modifications to the computer program 06/01/84 for of fsite dose calculations as described in GPUN response to 6.a.l.84-034)7 SMG' LING AfD ANALYSIS OF PLANT EFFLUENTS (MAP-5) 7.a Develop procedures for collection of 7.a.1 Investigate the collection, handling, and analysis 07/0l/84 representative plant effluent samples of high dose rate samples as described in 7.a, make including provisions for handling and the necessary procedural modifications, and perform analyzing high dose rate samples, time and motion studies for the resultant process.
7.a.2 Provide dose calculations based on the time and motion 07/01/84' studies for the process which results from 7.a.l.
84-03-08 SMFLING AND ANALYSIS OF PLANT EFFLUENTS (MM5-5) 8.a Install shields around all MAP-5 8.a.1 plete installation of shields described in 8 a.
06/01/84 cartridges.
8.b Document followup action taken on 8.b.I Document followup action taken on IEN-82-49 in 06/01/84 I EN-82-49.
regard to MAP-5, e.g., provide flow meter correction curves and complete the necessary procedural modi fIcations.
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Attachment I P&ge 7 POST ACCIDENT SMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR GPUN Targeted
' Item Action Completion No.
Inspection Report item No.
GPUN Action Date (Note 1)
Other PASS Commitments 9.a Complete Installation of seismic rack for bottled 06/01/84 air to serve as backup air for eductor In the s-Containment Atmosphere Sampling System.
9.b in order to insure that sufficient volume remains 04/01/84 in the makeup tank to receive the volume of reactor coolant sample which will be discharged, revise procedures to specify a 15 minute purge time and add a prerequisite to ensure a sufficient volume remains available in the makeup tank as freeboard.
9.c Determine the effect on Aux. Bldg. habitability 05/01/84 of the sink drain containing reactor coolant sample from the accident being flushed to the sump (consider both the drains from the IIquid and stripped gas samples).
9.d Verify the adequacy of the existing calculational 04/01/84 method for analysis of the RCS gas sample.
9.e Verify the accuracy of the pressure gauge used for 04/01/84 collection of the RCS gas sample.
9.f Perfom exposure analysis for obtaining a noble gas 05/01/84 sample at RMA-5 under post accident conditions.
NOTE I - Completion dates which show an asterisk Indicate that an additional submittal to NRC is required.
6471.k
t Page 1 POST' ACCIDENT SAMPLING AND MONITORING (IR 84-03)
DUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
1.b TMI-l currently has the capability of obtaining a post accident reactor coolant sample from either the loop B colo leg or the pressurizer sample points.
Samples from either of these points c'an be obtained between operating pressure and down to a pressure of approximately 114 psig within the 3-hour time limit and exposure criteria of NUREG 0737.
Whether the sample is taken from the loop or from the pressurizer is determined by a valve manipulation. Exposure to the technician would be the same for either sample point.
The post accident sampling procedure is being revised to incorporate the capability of taking a pressurizer sample.
For sampling at a reactor coolant system pressure lower than 114 psig, the normal sampling system has the capability of obtaining a decay heat sample, however, these lines are not currently shielded and personnel exposure would prohibit using this sample point shortly after an accident. G3UN does intend to modify the current system configuration to tie in the decay heat sample lines with the shielded reactor coolant sample line in the nuclear sampling room. If the decay heat system is taking a suction on the reactor building sump, this sample would not be representative of the coolant in the core region. However, under severe accident conditions, analysis of a reactor building sump sample could provide valuable information.
3.a.1 Procedure 1004.15 Rev. A cautions the chemistry technician to " Adjust CA-V-110 carefully since pressure of 125 PSIG downstream will cause CA-RV-5 to lift" in the caution before step 6.3.1.15.
Step 6.3.1.15 advises the technician to " Slowly open CA-V-110 to obtain pressure of 40-60 PSIG on CA6 PI".
Sufficient administrative guidance is given to the technician to prevent the inadvertant lifting of CA-RV-5.
The lifting of CA-RV-5 during flushing of obstructions from the tubing is prevented through the use of the valve lina-Up in section 6.4 of procedure 1004.15 Rev. 4.
The valve line-up does not cause the pressurization of the valves and piping downstream of the sample panel.
This portion of the piping is past the panel and assumed to be free of obstructions. Nitrogen can be directed through the tubing upstream toward the reactor coolant system to free the tubing of obstructions.
Because of this, the high pressure nitrogen is isolated from the 125 PSIG relief valve and the relief valve will not lift.
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Page 2 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03) j OUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
l 3.a.1 Due to the manual nature of the post accident sampling apparatus, (contd) leaks from the tubing or valve failures, if they occur, would be -
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isolated manually as soon as they were noted.
3.b.1 The resultant absolute pressure in the expansion bulb due solely to j
the expansion of dissolved gases from the reactor coolant sample is c
calculated to be 0.51 atm.
The inclusion of fission gases in the calculation would increase the pressure by less than 0.1%.
On the basis of this calculation, it is concluded that the expansion bulb volume is adequate for the collection of dissolved gas from a post accident reactor coolant system sample.
The details of this calculation are available at the site for review. This information was provided to one of the inspectors on January 25, 1984.
3.f.1 Inspection Report 84-03 is misleading in regard to the status of the containment Hydrogen Analyzers. Operating procedure (OP 1105-18) was approved February 10, 1983.
Test and calibration had also been completed earlier. However, as a result of a 10 CFR 21 notice from the vendor, the system underwent modifications. The system was turned back to the Startup and Test group and at the time of the inspection, problems which were discovered more recently were being resolved. 'It was not until after the inspection that this last round of testing by the Startup a'nd Test group was completed successfully on January 25, 1984.
Test and calibration surveillance procedures 1302-18 and 1303-4.23 for the containment hydrogen analyzers have been approved and surveillance testing is in progress to. implement these procedures.
As of this date, surveillance testing is complete for.one of the units.
The operating procedure is currently undergoing revision to incorporate recommendations which have resulted from testing.
3.g.1 TMI-l utilizes redundant in-line Hydrogen Analyzer systems. In the event one system were inoperative, the other system would not be affected. Therefore, it is our understanding that procedural provisions for collecting a grab sample for hydrogen analysis are not required by NUREG 0737.
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l-Page 3 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE N0.
4.1.b To minimize the dose contribution from unshielded auxiliary lines, procedures will be revised to prevent other samples from being taken which would introduce high activity water into these lines. Any " dose contribution from these lines would remain at the low levels which existed prior to accident conditions.
To prevent the dose contribution from airborne radioactivity (originatirg from the sink) from being higher than expected, procedures will be revised to verify ventilation air flow at the sample sink.
To minimize post accident exposure to the technicians, provisions will be made to install shielding for the sample sink drain line prior to initial collection of the post accident sample.
5.a.1 Prior to April 1,1984, GPU Nuclear will have the capability to analyze post accident samples for Chlorides, Boron and pH and be able to demonstrate this capability using actual procedures and equipment dedicated for use at TMI-1.
The auto sampler and auto controller to be used in the ion chromatographic analysis of Chlorides will be on site and available for use at that time. A minimum of three foremen and technicians will be trained on the use of the new equipment by April 1.
Although all technicians will eventually be trained on the use of this equipment, a minimum of three is considered sufficient to implement the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> Chloride analysis requirement.
Results to date on the use of a fluoroborate specific ion electrode to perform the Baron analysis for concentrations less than 500 ppm have been poor. GPU Nuclear is currently evaluating the lowest Boron concentration that would be present after an acc.ident.
The use of the pH mini probe is covered by existing procedures.
5.c.1 GPU Nuclear is analyzing the error that would be present in core damage estimates if stripped gas activities are not' included in the calculation.
If it is determined that stripped gas analysis results are required, procedural guidance will be provided.
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..?*l Page 4 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03)
DUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
5.d.1 The estimated radiation dose rate due to the concentration of isotopes from the ion exchange columns in the ion chromatograph are:
Contact 17 R/hr 1 ft.
28 mR/hr 3 ft.
3.2 mR/hr Through the use of the auto sampler and auto controller, the technician performing the chloride analysis will stand a minimum of 1 ft. from the instrument.
Most of the analysis is automated and could be monitored from much further away.
Therefore, there is no need to provide shielding for the ion chromatograph.
6.a.1 GPUN interprets the finding (84-03-06) to be in reference to refinements to the software for off site dose calculations which were not completed at the time of the inspection. These refinements include translation of the effluent monitor readout from the known calibration isotope to a specific isotope mixture based on the release pathway, the type of accident, and furthermore decay correcting'this mixture from the time of reactor shutdown.
GPUN has had conversion factors which convert effluent monitor readouts from counts per minute to microcuries per cubic centimeter for some time. Such conversions have not been a source of confusion.
We also have the capability to input post accident sample analysis results directly, should these results be available.
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