ML20111C200
| ML20111C200 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/06/1985 |
| From: | Liden E Public Service Enterprise Group |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8503150300 | |
| Download: ML20111C200 (12) | |
Text
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O PSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department March 6, 1985 U.
S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Thomas T.
Martin, Director Division of Radiation Safety and Safeguards Gentlemen:
NRC INSPECTION 50-272/84-45 AND 50-311/84-44 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET / LICENSE NOS. 50-272/DPR-70 AND 50-311/DPR-75 The referenced inspection conducted by members of your staff during the period November 26-30, 1984, consisted of a post-implemention review of the Post Accident Monitoring and Sample capability which has been provided for the Salem Generating Station (SGS).
In the course of this review, recommendations for improvement were made in several areas.
The following is PSE&G's response to those recommendations:
Item 272/84-45-01:
Containment Air Sampling Heat trace the section of the sample line leading to the cask / cart assemblies.
Repair the cask / cart assembly pressure indicator.
Response
1)
CASP Line Heat Trace A design change has been initiated to heat trace the section of containment air sample (CASP) line in question.
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-l Mr. Thomas T.
Martin 3/6/85 2)
Cask / Cart Pressure Indicator The pressure transducer on the cask / cart assembly was found to be out of calibration.
The transducer was recalibrated on December-10, 1984.
This item is now complete.
Item 272/84-45-02:
Chlorides Analysis Make arrangements for conducting a back-up chloride analysis of a grab sample.
Response
If the hydrogen concentration is verified to be greater than 10 cc/kg and the decision is made to delay the chloride analysis, an undiluted sample will be collected within the 96-hour period and retained for chloride analysis within 30 days.
Grab samples are collected in accordance with chemistry procedure CH - 3.1.002.
The preferred method of sampling and analysis is by routing a reactor coolant sample through the Liquid Sample Panel (LSP) to the analytical section of the in-line ion chromatograph (IC) within the chemical analysis panel (CAP).
Prior to routing reactor coolant to the CAP, the IC is calibrated with a 1 ppm Chloride standard in a boric acid matrix of 2000 ppm boron.
Any significant change in results from the standard curve indicates improper operation of the IC.
The Post Accident Sample System (PASS) Ion Chromatograph columns can be flushed to remove residual activity _ prior to any required maintenance.
Replacement of separator and fiber suppressor columns and IC valves can be accomplished in a short time period, if required.
Replacement parts for the IC are stored with the PASS spare parts in a readily accessible location.
Because of the potentially high personnel radiation exposures encountered in collecting, and' analyzing grab samples, and given the capability to repair / replace and calibrate the IC components in a short time period, the collection of grab samples.for back up chloride analysis is not anticipated.
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Mr. Thomna T. Martin 3/6/85 Item 272/84-45-03:
Boron Analysis Improve capability for an accurate analysis of grab samples for boron concentration
Response
The boron analytical procedure is being revised to provide better accuracy.
Training on this new procedure revision will be completed by. April 1, 1985.
Item 272/84-45-04:
pH Analysis Correct the in-line pH probe calibration tolerance to the-value specified in the procedures.
Response
The in-line pH probe calibration tolerance has been corrected.
This item is now complete.
Additionally, in-line measurement of pH is preferable over grab sample analysis for both technical and ALARA reasons.
The in-line analysis provides greater accuracy due to the absence of atmospheric interference and minimizes the potentially high personnel exposures that would be encountered during collection and analysis of a grab sample.
The pH probes utilized in the analysis have been used reliably for a number of years by the Nuclear and Chemical industries with no apparent disadvantages.
The CAP is designed to permit flushing of all lines to remove liquid radiation sources from the panel and'to permit repair and maintenance to be performed in a timely manner.
All panel lines can be flushed and the pH probe replaced and recalibrated within two hours.
Replacement probes are stored with the PASS spare parts in a readily accessible location.
Because of the potentially high personnel radiation exposures encountered in collecting and analyzing grab samples, and given the ability to replace and recalibrate the in-line pH probes in a short time period, collection of grab samples for back-up pH analysis is not anticipated.
Item 272/84-45-05:
Gross Activity and Isotopic Analyses Develop procedures for the acquisition and isotopic analyses-of stripped dissolved gas samples.
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Mr. Thomas T.
Martin 3/6/85
Response
The post-accident sampling procedure (CH-3.1.005) which governs the acquisition of stripped gas samples has been revised to include the correct volume, spectroscopy program and calculation needed for determining the activity of the reactor coolant.
An evaluation of the problems encountered during performance of the stripped gas comparative analyses is being conducted.
Appropriate corrective action is scheduled for completion by May 1, 1985.
Item 272/84-45-06:
Hydrogen Analysis Install radiation monitoring equipment in the sampling station.
Make preparations for sample collection and analysis based on an anticipated use, rather than starting when the decision is made to actually collect the sample.
Make provisions for assuring that the sampling station exhaust will pass through charcoal filters during emergency conditions.
Provide a reliable means to verify the status of the system valves.
Response
1)
A design change has been initiated to install an area monitor in the pass room.
Audio and visual alarm indications will be provided outside the sampling station (PASS room) door.
2)
The emergency plan implementing procedures will be revised such that when an alert or higher classification of emergency is declared, a request to " warm-up" the post accident sampling system will be made.
These procedures will be finalized by April 1, 1985.
3)
The emergency plan implementing procedures and associated emergency instructions will be revised such that the sampling station (PASS room) ventilation will be exhausted through the appropriate charcoal bank.
These procedures will be finalized by April 1, 1985.
1 Mr. Thomas T.. Martin 3/6/85 4)
Work orders were issued and repairs performed on the valve position indicators for the PASS sampling station.
However, because these indicator failures have been recurring, a deficiency report has been initiated to seek permanent corrective action.
Additionally, a back-up means of determining whether a valve has properly opened has been established.
This calls for the operator to continue with the procedural steps until flow is later verified in the procedure.
Chemistry procedures CH-3.1.001, CH-3.1.002, CH-3.1.003, CH-3.1.004, CH-3.1.005, CH-3.1.007, and CH-3.1.013 are being revised to reflect this reliable backup means of flow determination.
Item 272/84-45-07:
Noble Gas Effluent Monitor, Item II.F.1-1 Procedures should be developed and appropriate training-provided so that control room liaisons would be sufficiently conversant with the control of the AXM-1 so as to be able to make full interrogation of its information storage capabilities.
The shielding of the bulk filter assembly should be accomplished as expeditiously as practicable.
The energy responses of the AXM-1 detectors, as installed, should be documented by the licensee.
If they affect the interpretation of its readout by more than a factor of two, suitable corrections should be provided in the procedure for the interpretation of the indications.
The licensee should promptly resolve the maintenance and reliability problem due to steam leaks around'the steam line detectors.
Procedures to implement the use of the Porter document for the interpretation of steam line monitor data should be finalized.
Response
1)
A procedure for data interrogation of the AXM-1 will be issued and training of control room liaison personnel will be completed by July 1, 1985.
2)
Design changes have been initiated to install shielding around the bulk filter assembly.
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Mr. Thomas T. Martin 3/6/85 3)
The energy response of the AXM-1 detectors has been documented in a recent report prepared by Porter Consultants.
Appropriate corrections will be added to the existing procedures, where needed, by May 1, 1985.
4)
The steam leak on 1R46B channel has been corrected and all channels are currently operable.
Se veral modifications have been-performed on these detector chambers to reduce moisture in the detector environment.
This item is now complete.
5)
The appropriate emergency plan implementing procedures will be revised to include the energy response study results of Porter Consultants.
These procedure revisions will be completed by May 1, 1985 Item 272/84-45-08:
Sampling and Analysis of Plant Effluents Item II. F.1.-2.
The intake line should be maintained at a temperature of at'least 150*F to minimize the possibility of condensation and to minimize the possibility of the plate-out of elemental iodine in the line.
The capability of the system to obtain a representative sample under accident conditions should be documented.
A shielding design analysis should be conducted to establish that the persons responsible for the collection and transport of samples from the existing system can do so within the requirements of GDC 19.
The sampling procedures should incorporate a step for the i
correction of flow meter readings relative to the pressure in the sampling system at their location.
As an alternative, the licensee should investigate the ability of the AXM-1 Accident Range Monitor to obtain a sample in a manner that more fully complies with the requirements of NUREG-0737, II.F.1-2, than does the currently utilized system.
Response
1)
A design change has been initiated to upgrade heat tracing in order to minimize condensation and elemental iodine plate-out.
2)
The representativeness of samples from the AXM-1 system is currently being re-evaluated and documented.
This documentation will be completed by May 1, 1985.
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'Mr.' Thomas T. Martin 3/6/85 3)
A shielding design analysis for R45 sample collection and transport is currently in progress.
This analysis will be completed by May 1, 1985.
4)
Correction curves for sample volume versus system pressure have been developed.
The chemistry procedure governing this activity (CH-3.5.073) is currently being revised to incorporate the curves.
This item will be completed by April 1, 1985.
5)
The possibility of employing the 100 cc/ min grab sample pallet assembly of the AXM-1 is currently being evaluated.
This evaluation will be completed by May 1, 1985.
Item 272/84-45-09:
In-Containment High Rad Monitors, Item II.F.1.-3 There was no data in the reports ( En vironmental i
Oualification Report No. 950.301 & lEC-0754 for the High l
Range Containment Monitor) to support Environmental Oualification of L'he installed, High Range Monitor cable connector termination assembly.
Response
The qualification infarmation requested for the installed High Range Containment Monitor Cable Connector Termination Assembly is attached.
The qualification data is provided in the Victoreen Test Report No. 950.301 which includes Wyle Test Report No. 45050-1, Victoreen High Range Containment Monitor Cable Termination Procedure No. 910077, and Victoreen Test Plan No. 907351.
During the initial qualification tests, Victoreen had difficulty in properly connecting and sealing the co-axial connector to a hermetically sealed connector body manufactured by the Hermetic Seal Corp.
Victoreen stated they were not successful in finding a suitable combination of epoxy, silicon rubber or other type of sealing compound for making this connection but this did not preclude the user from finding a suitable connector.
To overcome this hardware deficiency, Victoreen improvised three different types of installation for the LOCA tests which
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did not rely on sealing compounds to prevent the entrance of contaminated steam into the seal area.
Three separate tests relative to the detector and cable were conducted that successfully survived the LOCA conditions.
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Mr.LThoman T. Martin. 3/6/85 Victoreen' concluded that "it is very critical that all vapor / liquid sprays be kept away from the electrical connection-points".
To prevent this from occurring during actual operation, Victoreen issued High Range Containment Monitor Cable Termination Procedure No. 910077.
This procedure was utilized for installation of these assemblies.
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As the. actual LOCA tests did not utilize qualified connectors and seals, it was required that the. detector end of the cable be inserted into a flexible metal hose with the tube fitting of the hose swaged to the cable connector backshell.- From the flexible steel tubing the cable then entered a stainless steel
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pull-box either directly swaged to the flexible tubing or via rigid stainless steel tubing swaged to both the pdll-box and.
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the flexible tubing.
Additional flexible tubing was similarly used to join the pull box to the backshell of the penetration-connector.
Although the test procedure required a totally encapsulated assembly installation, the Victoreen installation procedure i
terminated any special sealing requirements at the pull-box.
The assembly installation followed this procedure as written, but with the addition of environmentally qualified Conax Connectors and BIW Coaxial cable, and the use of solid conduit i
from the pull-box to a cable tray.
The cable was then routed 1
without conduit in the cable tray to the electrical penetration.
A subsequent report provided by Victoreen specifically recommended that the cable be enclosed in conduit up to the penetration and then sealed.
This recommendation has been i
incorporated by Victoreen to provide added assurance that the j
extremely small current signals generated by the sensor will not be affected by moisture intrusion.
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The Salem assembly installation which utilizes qualified l
components and cable, provides assurance that the system is j
environmentally qualified and meets the requirements of NUREG 0737, Item ll.F.1.
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Item 272/84-45-10:
In-Containment High Rad Monitors Item II.F.1-3 Submit the design for the current installation location to NRR for review and approval.
Response
The requested information. was. submitted for NRR review by l
PSE&G letter dated-January :2, 1985.
Additionally, the in-situ-calibration of these monitors was satisfactorily completed on December 27, 1984.
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'Mr. Thomas T.-Martin 3/6/85 Item 272/84-45-11:
Improved In-plant Iodine Instrumentation Under Accident Conditions, Item III.D.3.3
' Procedures for collection, analysis, and handling of samples under accident conditions should be finalized.
Response
The emergency plan implementing procedures governing the monitoring of the plant airborne radiciodine levels have been finalized and approved.
Training on these procedures will be completed by July 1, 1985.
Although unrelated to the post-implementation review, the following items were identified in the referenced inspection report.
These items have been dispositioned as indicated:
Item 272/84-45-12:
Respirator Training The following deficiencies were identified:
Practical factors (donning, removal, and negative-pressure checking ) are not included in the training.
Inadequate emphasis is given on the topic of relief from respirator use, i.e. all situations prompting relief from respirator use as listed in 10 CFR 4
20.103c.3 are not described to the worker.
The training does not familiarize the worker in the mechanics of check out and return of respirators, including forms to be filled out and the method for taking nasal smears.
Response
The Respirator Training Program will be enhanced to include training in all of the above areas.
The program will be revised and training to the revised program will start April 30, 1985.
Items 211/84-44-01:
Lapse of Radiological Cont'rols Reports 10 CPR 19.12 " Instruction to Workers" states, in part, that workers "shall be instructed of their responsiblity to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licenses or unnecessary exposure to radiation or radioactive material."
To ensure compliance with this requirement, the licensee stated that the LRC procedure would be revised and steps taken to clarify worker misconceptions regarding the LRC system.
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'Mr. Thomme T. Martin 3/6/85
Response
Lapse of Radiological Controls procedures (RPl.025 and 1.030) have been revised to require proper documentation of radiological occurrences at the Salem Generating Station.
If you have any questions, please do not hesitate to contact us.
Sincerely, s
/
E.
A.
Liden Manager - Nuclear Licensing and Regulation Attachment C
Mr. Donald C.
Fischer (w/o attachment)
Licensing Project Manager Mr. James Linville (w/o attachment)
Senior Resident Inspector I-r i
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875584 Published by VICTOREEN, INC.
Printed in U.S.A.
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USER CAUTION This system is intended solely for the detection and measurement of ionizing radiation.
It should be used only by persons who have been trained in the prope r interpretation of its readings and the appropriate safety procedures to be followed in the presence of radiation.
All instructions and warnings contained in this manual or on a component instrument must be read before use and must be strictly followed.
Failure to follow these instructions and warnings may result in inaccurate readings and/or user hazard.
Indicated battery and other operational tests must be performed prior to each use to assure that the component instrument is functioning properly.
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