ML20086A506
| ML20086A506 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/12/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM GNRO-91-00167, GNRO-91-167, NUDOCS 9111190183 | |
| Download: ML20086A506 (3) | |
Text
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l November 12, 1991 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention:
Document Control Desk l
SUBJECT:
Grand Gulf Nuclear Station-
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Unit 1 l
Docket No. 50-416 l
License No. NPF-29 Pos: Accident Sample Offsite Analysis l
GNR0-91/00167 Gentlemen:-
In 1982, GGNS's Chemistry Department performed testing of the newly installed TEC Post Accident Sampling System.(PASS) and developed-
. laboratory methods.to meet-the requirements of Reg. Guide 1.97 and NUREG 0737.
The laboratory test methods developed as primary and backup analyses for Post Accident Sampling were verified against the chemical
-test-matrix-in Attachment 1 of NUREG 0737, II.B.3.
The results of this testing and-the achieved accuracies were-submitted to the NRC in a letter dated August 25, 1983 (AECM-83/0465).- Rather than perform the induced radiatio ofield-portion of the test matrix, GGNS elected to contract.this,
' service from an offsite laboratory.
In AECM-83/0465,' Mississippi Power and. Light stated that a signed -
agreement-had been obtained with Oak-Ridge-National Laboratory-(ORNL) to perform the offsite analyses.- ORNL agreed to receive and perform analyses of PASS samples originating at Grand Gulf Nuclear Station (GGNS) in the event of GGNS experiencing a 1% or greater fuel failure.
However, in May;1987. GGNS was notified by letter that-0RNL would no F
longer be able to provide this service as they were not allowed to
- duplicate services offered by a private industry source, Babcock and Wilcox~(B&W).
The agreement was forced to be terminated.
GGNS then initiated a contract-with B&W in August of 1987 for off-site PASS analysis
-services.
At ~ the most recent PASS Owner's Group Meeting, B&W indicated that their program had not been fully tested against the NUREG 0737 Standard Test Matrix-and-thus was not suitable for use as a comparison cross check'for GGNS's program. _ We are not aware of any other qualified testing service.=
~9111190183 911112 PDR -ADOCK 05000416 F'
PDR.
~SPRSEPT/SCMPFLR - 1 1sooss N
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November 12, 1991 GNRO-91/00167 Page 3 of 4 cc:
Mr. D. C. Hintz Mr. J. L. Mathis Mr. R. B. McGehee Mr. N. S. Reynolds Mr. H. L. Thomas Mr. Stewart D. Ebneter Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Eegulatory Commission Mail Stop 13H3 Washington, D.C.
20555 s
A L
SPRSEPT/SCMPFLR - 2
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November 12. 1991 GNRO-91/00167 Page 2 of 4 Through a conversation with Mr. Frank Witt of NRR on June 28, 1991, it is our understanding that the IE4 rad /gm gamma radiation field portion of
-NUREG 0737 standard test matrix was intended to qualify PASS in-line monitoring instrumentation which could be subjected to high raciation fields from the reactor coolant in the sample system piping.
The GGNS PASS system's primary method of sampling is grab sampling. Committing to use ORNL, as described in paragraph 4 of AECM-83/0465, was only intended as a verification for GGNS's in-lab analyses of-grab samples, in lieu of using the IE4 Rad /gm for verifying in-lab analyses methods. As the IE4 rad /gm testing was not applicable to laboratory analysis of grab samples, our original: testing commitment exceeded the intent of NURdG 0737.
GGh5 developed grab nample procedures which have been sub'mitted to the NRC,-in AECH-83/0465, to meet the acceptance criteria set forth in Reg Guide 1.97 and NUREG 0737.
These procedures also satisfy License Condition 2.C (44) (c) (ii).
Based on-the clarification from Mr. Witt of the IE4 rad /gm portion of the NUREG 0737 test matrix, our relience on PASS grab sampling rather than in-line monitoring and the unavailability of a qualified testing service, GGNS is withdrawing our commitment to maintain a contract with an offsite facility to perform backup analyses for PASS. This change has been reviewed under 10CFR50.59 and does not constitute an unreviewed safety c uestion.
As requested by the NRC, we are providing this letter to c ocument_ our changed commitment.
Please feel free to contact Riley Ruffin at (601) 437-2167 should you wish further information.
Yours truly, w r%
WTC/RR/cg cc:
(See following page)
SPRSEPT/SCMPFLR - 1
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