ML20148R969
| ML20148R969 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/13/1988 |
| From: | Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148R900 | List: |
| References | |
| 50-424-87-68, NUDOCS 8802020315 | |
| Download: ML20148R969 (21) | |
See also: IR 05000424/1987068
Text
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UNITEo STATES
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NUCLEAR REGULATORY COMMISSION
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Report No..
50-424/87-68
Licensee:
Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket No.-
50-424
Facility Name:
Vogtle, Unit 1
License No.:
Inspection cond
d:
Dec m er 7-11, 1987
/'/7#
Inspector:
w/
P.'G.-Stodda'r P
Date Signed
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Obb.jd
/ //y /D
Approved by:
J B Kahle, Secti'on Chief
D' ate 41gned
D
ion of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of Post
Accident Sampling System evaluation, investigation of technical aspects of
allegations, and followup on previously identified items.
Ress
One violation was identified - f ailure to follow procedures. Three
schedui..d maintenance or calibration checks were not performed in the required
time periods.
8802020315 800120
ADOCK 05000424
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- G. Bockhold, General Manager
- R. Bellamy, Plant Manager
- S. Ewald, Manager, Health Physics and Chemistry
- S. Hallman, Chemistry Superintendent
- W. E. Mandy, Quality Assurance Supervisor
- P. Jackson, Engineer, PASS System
- A. Stalker, Corporate Health Physics and Chemistry
- A. Desrosiers, Superintendent. Health Physics and Chemistry Support
Other licensee employees contacted included engineers, technicians,
operators, security office members and office personnel.
Other Organization
T. Harkins, Bartlett Corporation, PASS Engineer
R. Cisio, Bartlett Corporation, Electronics Engineer
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on December 11, 1987,
with those persons indicated in Paragraph 1,
above.
The inspector
described the areas inspected and discussed in detail the inspection
findings listed below.
No dissenting comments were received from the
licensee.
One probable violation was discussed - Failure to follow procedures
required under Technical Specification 6.7.1.b.
Periodic surveillances
were missed on three occasions. The licensee acknowledged the inspector's
finding regarding this matter and stated that corrective measures had
already been initiated to prevent a recurrence.
Two inspector followup
items were identified in areas of the Post Accident Sampling System
evaluation where a full evaluation could not be made due to system
component malfunctions. The licensee noted these items and indicated that
action had been taken toward resolution of the system malfunctions. The
licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation (IV) 50-424/87-34-01:
Failure to follow procedure for
waste gas releases, resulting in uncontrolled release of radioactive gases
to the environment.
The inspector reviewed revised procedures and
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documentation of special training given to operators to prevent future
recurrence.
Licensee actions were considered adequate and the matter is
closed.
4.
Summary of Evaluation of the Post Accident Sampling System (PASS)
The Post Accident Sampling System (PASS) was evaluated for conformance to
the criteria of Section II.B.3 of NUREG-0737, "Clarification of TMI Action
Plan Requirements" and related generic letters to all power reactor
licensee applicants and licensees dated March 20, 1980.
The eleven
criteria of NUREG-0737 contained some multiple requirements; for purposes
of this evaluation, the criteria were re-stated as 17 separate items and
evaluated and reported in that context.
However, for purposes of
conformance to NUREG-0737, the following Table I summarized the evaluation
against the 11 NUREG-0737 criteria of Section II.B.3, Post Accident
Sampling Capability.
TABLE I
INSPECTION SUhMARY
Does Not
Meets all
Meet All o'
Criteria
of Criteria
Criteria
Reasons
1
X
2
X
3
X
4
X
analysis
or stripped gas was
outside of accuracy
guidelines
5
X
6
x
7
X
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8
X
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X
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10
X
Isotopic
radioactivity
analyses in reactor
coolant or stripped
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gas were outside of
accuracy guidelines
11
X
Details of the evaluation and PASS areas which did not fully meet the
evaluation criteria are provided in the subsequent sections 6f this
inspection report. Attachment 1 of this inspection report provides the
details of the evaluation against seventeen criteria derived from
NUREG-0737 and implementing correspondence.
5.
PASS Description
The Vogtle Unit 1 PASS was built by the Sentry Corporation, Oconomowoc,
WI, and included components supplied by other vendors.
The PASS was
designed for full remote sampling and analysis for all of the measurements
or analyses specified in Section
II.B.3,
Post Accident Sampling
Capability, of NUREG-0737.
The PASS installed at Vogtle Unit 1, together with a second identical PASS
installed at Vogtle Unit 2 but not yet placed in operation, was the first
operational Sentry PASS system incorporating in-line gamma spectrometry
for reactor coolant system (RCS) and containment sump samples (liquid) and
for RCS stripped gas and containment ctmosphere samples.
No violations or deviations were identified.
6.
PASS Procedure Review
The inspector reviewed licensee procedures for the testing, calibration,
maintenance, and operation of the PASS during this inspection and prior
inspections 50-424/87-09,86-119 and 86-137.
The procedures appeared to
be adequate and had been reviewed and approved by appropriate plant
supervisors in accordance with Technical Specification requirements.
Since the Vogtle Unit 1 PASS was the first vendor system (of this model)
to be placed in operation, it was necessary for the licensee to develop
test, calibration, maintenance and opernting procedures based on the
vendor's design description and recommended operating procedures and to
modify
or
revise
those
procedures according
to
plant-specific
circumstances or conditions encountered during installation, inspection
and preliminary acceptance tests. In doing so, the licensee was not able
to consult with other licensees as to suggested courses of action to
resolve problems or questions which arose.
However, licensee personnel,
with technical assistance from the vendor, were able to prepare the
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necessary procedures and to validate those procedures through operation of
the PASS.
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No violations or deviations were identified.
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7.
PASS Training
The inspector reviewed the licensee's training program for operation of
the PASS during Inspections 50-424/87-34 and 87-09. In those inspections,
the licensee's training program appeared to be adequate.
Training
consisted of classroom and "hands on" sessions and included vendor
participation.
No violation or deviations were identified.
8.
PASS Acceptance Testfng
The inspector reviewed appropriate portions of acceptance and preoperation
tests of the PASS during prior inspection 50-424/87-09.
The requisite
tests appeared to have been completed satisfactorily and had been reviewed
and approved in accordance with licensee's established procedures.
No violations or deviations were identified.
9.
PASS Surveillance Checks and Periodic Calibration Checks
The
inspector
observed while
licensee personnel
performed daily
surveillance checks as specified in Procedure 35640-C.
All steps in the
procedure were accomplished as described and minor adjustments were made
as necessary.
The engineer performing tne surveillance checks explained
each step to the inspector, who was furnished with a copy of tne
surveillance procedure, and in doing so demonstrated an adequate level of
familiarity with the system and the surveillance procedure. The inspcctor
also reviewed records of monthly periodic surveillances and system
calibration.
Several PASS procedures concerned with PASS component or
subsystem calibration required surveillance tests or checks at monthly
(not to exceed 45 days) intervals.
Three instances were identified in
which recalibration or system testing was not performed within the
required time frame.
These were:
a.
Procedure 35611-C, Remote Analysis With the Post Accident Sampling
System. System testing was performed on June 15, 1987, and next on
August 17, 1987 -- an interval of two months plus two days. This was
in violation of the procedural requirement for system testing at
intervals not to exceed 45 days.
b.
Procedure 35625-C, Calibration of the Post Accident Sampling System
Dissolved Oxygen Monitor.
Calibration was performed on March 10,
1987, and next on July 14, 1987 -- an interval of four months plus
four days. This was in violation of the procedural requirement for
calibration at intervals not to exceed 45 days.
c.
Procedure 35629-C, Recalibration of the Post Accident Sampling System
lon Chromatograph.
Calibration was performed on June 10, 1987 and
next on August 16, 1987 -- an interval of two months plus six days.
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This was in violation of.the procedural requirement-for recalibration.
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'at intervals.not to exceed 45 days.
Technical Specification 6.7.1.b req ui're s the licensee to implement
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established procedures,
including these established for the -PASS
referenced' in NUREG-0737.
The instances detailed above represented
- multiple. examples of failure to implement p cedures by failure to perform
procedural requirements for periodic system tests within the specified
time limits.
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(0pened) Violation, 50-424/87-68-01 - Failure to perform procedural
requirements in accordance with specified periodic tests of the post
accident sampling system (PASS).
10.
PASS Facility Shielding and Dose Calculations
NUREG-0737 Criterion 6 of Section
II.B.3,
Post Accident Sampling
Capability, specifies that the design basis for- plant equipmeret for
reactor coolant and containment atmosphere sampling and analysis must -
assure that it is possible to obtain and analyze a sample without
radiation exposures to any individual exceeding 5 rem to the whole body or
75 rem to the extremities (General. Design Criterion 19, Appendix A, 10 CFR. Part 50).
The inspector reviewed the licensee's shielding and dose calculation
study.
The. study was conducted by Bechtel in December 1986, and included
an extensive time-motion study.
Dose calculations were based on Bechtel
calculation package X6CDJ.08 and on Plant Vogtle operating procedure
35620-C, Rev. 1.
The licensee at the time of the inspection was using
operating procedure 35611-C,
Rev. 3,
dated December 6,
1987.
The
inspector reviewed portions of the above-referenced documents and verified
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selected calculations.
The documentation appeared to be adequate and
satisfactorily addressed the principal points of concern in the matters of
shielding and dose calculation.
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.No violations or deviations were identified.
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11.
PASS Design Requirements
NUREG-0737 Criterion 3 (II.B.3:
PASS) specifies that reactor coolant and
containment atmosphere sampling CJring accident conditions shall not
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require an isolated auxiliary system to be placed in operation in order to
use the sampling system. The inspector reviewed the PASS design and PASS
operating procedures and determined that no isolated auxiliary system
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would have to be placed in operation in order to use the sampling system.
As a point of clarification, it is noted that "isolated auxiliary system"
includes such systems as the Residual Heat Removal System or the Primary
Coolant Letdown System; reference to sampling isolation valves or sampling
piping or control valves as "isolated auxiliary systems" was not intended
or inferred.
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No violations or deviations were identified.
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PASS Design Requirements for Time to Collect and Analyze Samples
-NUREG-0737 Criterion 1 specifies that the licensee shall
h' ave the
capability to promptly obtain reactor coolant samples and containment
- atmosphere samples.
The combined time allotted for sampling and analysis
should be three hours or less from the time a decision is made to take a
-sample.
The inspector observed reactor coolant liquid and containment atmosphere
sampling and analysis operations on several occasions during the
inspection.
In each instance, the licensee .was able to obtain a sample
and analyze the sample within the required three hours. In one case, the
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licensee was demonstrating an alternative or backup method f or obtaining a
"grab" sample of. undiluted reactor coolant when the mechanism for coupling
the liquid sample injection system to the shielded shipping cask
containing the samole collection bottle could not be lowered into
position. After several attempts to make the coupling were unsuccessful,
the licensee utilized a . second backup system and obtained a diluted
reactor coolant sample and was able to perform an analysis of that sample
within the specified time.
In determining the cause of the malfunction,
it was found that a microswitch safety device had shifted position
slightly, preventing the movement of the coupling device. The microswitch
was repositioned and the system was operated. several times to assure
correct operation. On the following day, the inspector observed another
sampling operation, at which time the system functioned properly and a
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sample was taken and analyzed within the prescribed time.
On the basis of the demonstrated sampling and analysis operations, the
ins.pector concluded that
the licensee had the capability to promptly
obtain reactor coolant samples and containment atmosphere samples and to
analyze the collected samples within a time frame of three hours.
No violations or deviations were identified.
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13.
PASS Onsite Nonradiological Analysis Capability
NUREG-0737, Item II.B.3, Criteria 2(b), 2(c),
4,
5,
and 7 specify
requirements or recommendations for determination of hydrogen
in
containment atmosphere and of boron, chloride, dissolved oxygen, hydrogen
(or total dissolved gas), and pH in reactor coolant. With the exception
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of hydrogen in reactor coolant, the licensee adequately demonstrated the
u oabilitv for nonradiological sampling and analysis.
The measurement of hydrogen in primary coolant using the in-line gas
chromatograph produced results which were significantly below those
produced in the concurrent normal sample analyses of primary coolant. The
licensee was not able to demonstrate the required accuracy.
Investigation
by licensee staff into the underlying cause appeared to indicate the
presence of a vacuum leak in the gas evacuation chamber of the gas
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chromatograph.
The licensee was not able to resolve this problem as of
the end date of this inspection.
This matter was identified as an Inspector Followup Item and will be
reviewed during a later inspection.
(0 pen) Inspector Followup Item (IFI) 50-424/87-68-02, Review resolution of
low hydrogen / dissolved gas analysis results in primary coolant PASS
samples.
14.
PASS Onsite Radiological Analysis Capability
NUREG-0737 Criteria 9 and 10 and Attachment No.1 to the generic letters
to all power reactor applicants and licensees dated March 20, 1980,
require that the licensee's radiological and chemical sample analysis
capability include the following provisions:
a.
Establish an onsite capability for quantification of noble gases,
iodines, and nonvolatile radionuclides in the reactor coolant which
may provide an indication of the degree of core damage,
b.
The range of activity that the equipment must be capable of measuring
for a reactor coolant sample is from 1 pC1/g to 10 Ci/g (total
activity).
c.
The results of gamma spectral measurements should be accurate within
a factor of 2 across the entire range.
The Sentry PASS for Vogtle Unit I had an in-line capability for analysis
and measurement of reactor coolant and containment sump liquid samples and
of containment atmosphere and RCS stripped gas samples.
Vendor and
licensee tests of the range of activity that the various components of the
PASS were capable of measuring, in diluted or undiluted modes of
operation, appeared to confirm that the PASS was capable of measuring
reactor coolant samples from 1 uC1/g to 10 C1/g and containment atmosphere
samples
ranging
from normal
operating
levels
to
approximately
1 E+05 uCi/cc (total activity).
The inspector observed several sampling rens of the PASS.
The first
sample analyzed by the in-line gamma spectrometer indicated activity
concentrations in reactor coolant which were higher than those obtained
concurrently with the normal sampling system and the in plant laboratory
gamma
spectrometer.
Licensee personnel
attempted to resolve the
discrepancy by flushing out all system sample lines to reduce suspected
radiation background.
When the operator tried to run the spectrometer
following the attempt to reduce background, there was an apparent
electronics failure in the transmittal of data from the spectrometer to
the computer used for interpretation of the spectra.
As a result, the
licensee was unable to successfully analyze the RCS liquid sample, or the
RCS str pped gas sample containment atmosphere sample using the in-line
spectrometer for the remainder of the inspection.
However, the licensee
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was able to utilize the backup sampling and analysis systems which had
been incorporated to fulfill the requirements of NUREG-0737 Criteria 9 and
10 and of Attachment 1 (referenced in the lead paragraph of this section
of this inspection report). The systems problem in the communication link
between the spectrometer and the computer was listed as an inspector
followup item and will be reviewed during a subsequent inspection.
The licensee demonstrated the PASS built-in backup sampling systems by
collecting undiluted and diluted (1:1000) samples and analyzing them
onsite.
Comparison of these analyses to the analysis of a concurrent
reactor coolant sample procured at the normal sampling sink yielded the
following results:
PASS:
Reactor
PASS:
Reactor
SAMPLE SINK:
Normal
Coolant Sample -
Coolant Sample -
Nuclide Undiluted uCi/ml
Diluted 1000:1 uCi/ml*
Sample uCi/mi
Na-24
5.36E-02 + 0.04E-02 8.98E-02 + 0.28E-02 5.69E-02 + 0.09E-02
Co-58
9.90E-04 7 1.22E-04 6.92E-03 7 0.92E-03 6.49E-04 7 2.21E-04
1.15E-04{0.56E-04
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3.30E-03 + 0.20E-03 5.10E-03 + 1.29E-03 3.28E-03 + 0.31E-03
I-133
1.88E-03 7 0.07E-03 2.86E-03 7 0.52E-03 2.02E-03 T 0.19E-32
1-134
8.37E-0330.82E-031.03E-0210.42E-025.46E-0330.70E-03
- Concentration corrected for 1000:] Dilution
With the exception of the diluted RCS PASS sample value for Co-58, all of
the undiluted and diluted RCS PASS Sample analysis values were within a
factor of two (2) of the analysis of the normal RCS sample for the same
time period. Since 9 out of 10 values were within the specified factor of
two, the analysis values were considered acceptable.
(0pened) Inspector Followup Item (IFI), 50-424/87-68-03, Review licensee
resolution of data transmission problem between the PASS gamma
spectrometer and the system computer used in spectrum analysis.
No violations or deviations were identified.
15.
Allegation Followup (99014)
The ' nspector conducted a review of circumstances surrounding Allegation
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RII-87-A-0122 on December 8-10, 1987.
The allegation stated that the
Plant Vogtle FSAR, in Section 9.1.2.1.2,
committed to sample liquid
wastes, analyze before release and maintain records (of analyses and
release documentation) but (the licensee) was not sampling or analyzing
wastes being dumped into the turbine drains. The inspector reviewed the
FSAR files and observed that Section 9.1.2 was concerned with spent fuel
storage and was unrelated to radioactive liquid waste processing,
analysis, and release.
Further, there was no indication in either
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licensee or NRC files that a Section 9.1.2.1.2 has ever oeen present in
the Vogtle FSAR.
The inspector observed that the alleger may have intended to reference
Plant Vogtle FSAR Section 11.2, Liquid Radwaste Processing Systems,
Subsection 11.2.1.2, Controlled Release of Radioactivity, which represents
the licensee's commitments for the sampling and analysis of radioactive
liquid effluent streams.
It is noted that Subsection 11.2.1.2, does not
specifically commit the licensee to sampling and analysis of all pctential
radioactive liquid waste streams prior to release. Liquid effluents from
the turbine building and from the plant cooling water discharge are
continuously monitored to detect inadvertent releases of radioactive
materials by these pathways.
In the absence of more information specific to the alleger's concerns, it
is recommended that this matter be closed.
No violations or deviations were identified.
16.
Followup on Inspector Identified Problems (92701)
a.
(Closed) Inspector Followup . Item (IFI) 87-09-01, Evaluate Post
Accident Sampling System operation af ter plant has operated at least
30 days at full power and correlate analytical measurements against
normal sample results. See Paragraphs 4 through 12 and Attachment 1
of this inspection report.
This-item is closed.
b.
(Closed) Inspector Followup Item (IFI) 87-34-02, Review allegation of
procedural violation involving order fer contractor mechanics to
torque radwaste filter lid holddown bolts to 20 foot pounds above
specified value.
This allegation was investigated in part in
Inspection 50-424/87-34.
In that inspection report, it was noted
that a procedure revision had been made to permit torquing of the
holddown bolts to 15 foot pounds above the previous procedure value;
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during that inspection, however, press of other activities involving
a large volume liquid radwaste spill did not permit the inspector to
attempt to contact unidentified contract workers employed by Chicago
During this inspection, the inspector was
informed that the CB&I contract had oeen terminated and that no CB&I
personnel were currently onsite.
In the absence of specific
information concerning the identity of the CB&I workers who may have
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been involved in mechanical work in the Interim Radwaste Facility in
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March 1987 -- the period concerned in the allegation -- further
investigation into this allegation was not considered within the
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scope of the inspector's assignment. This matter was referred to the
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original investigating organization to determine the need for further
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investigation.
This item is closed.
c.
(Closed) Inspector Followup Item (IFI), 50-424/86-137-03, Review
preoperational procedures for boron recycle system and associated
waste evaporator.
The inspector was informed that the licensee does
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not plan to use the boron recycle system or the associated waste
evaporator.
The USNRC was informed of this position in letter from
R. E. Conway, Georgia Power, to Dr. J. N. Grace, Region II, USNRC,
dated January 2, 1987.
This item 1s closed.
d.
(Closed)
Inspector
Followup
Item
(IFI)
86-119-01,
Review
environmental laboratory procedures for air cartridge placement.
gamma
system efficiency checks,
audit frequency,
and sample
presentation.
The inspector reviewed the licensee's IFI closure
package,
which
contained copies of environmental
laboratory
procedures which had been revised to address the concerns of this
IFI.
The inspector reviewed selected sections of procedures
PSL-12450.613, PSL-12450.703, and PSL-12450.625.
The procedures
appeared to satisf actorily address the principal concerns, including
audit frequency, filter placement relative to the front side of
charcoal cartridges, gamma spectrometer calibration frequency, and
preservation
of
composited
samples
to
prevent
plateout or
deterioration.
This item is closed.
e.
(Closed) Inspector's Followup Item (IFI) 50-424/86-119-07, Modify 90
bend on the intake line of the environmental air samplers.
The
inspector reviewed the licensee's IFI closure package, which included
a drawing showing revision of the 90 bend to a straight line intake.
A memorandum in the closure package stated that all of the 90 elbows
on the Vogtle area environmental air monitors had been replaced on
January 13, 1987.
Based on the licensee's written statements, the
item is closed.
f.
(0 pen) Inspector Followup Item (IFI) 50-424/86-37-04, Review final
resolution between NRC and applicant regarding filter system
clarification for the four ESF systems. This matter was not reviewed
during this inspection.
g.
(0 pen) Inspector Followup Item (IFI) 50-424/86-92-01, Review of
chemistry staff training.
This matter was not reviewed during this
inspection.
h.
(0 pen) Inspector's Followup Item (IFI) 50-424/86-137-04, Review
preoperational tests of waste gas system which were to be completed
by December 15, 1986.
This matter was not reviewed during this
inspection.
1.
(0 pen)
Inspector Followup Item (IFI) 50-424/86-137-05, Review
installation of HEPA filters and charcoal adsorbers in ESF and
non-ESF ventilation and exhaust treatment systems.
This matter was
not reviewed during this inspection.
J.
(Open)
Inspector Followup Item (IFI) 50-424/86-137-06, Review
applicant evaluation of mechanism of sampie transport for (gaseous)
iodine in long sampling lines.
The licensee informed the inspector
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that this matter was scheduled for in plant tests and evaluation
during the first refueling outage.
This matter remains open.
k.
(0 pen) Inspector Followup Item (IFI) 50-424/87-09-02, Review results
of DOP and freon leak tests of TSC filters and charcoal adsorbers.
This matter was not reviewed during this inspection.
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ATTACHMENT 1
EVALUATION CRITERIA FOR
POST ACCIDENT SAMPLING SYSTEMS AND
ANALYSIS OF SAMPLES:
Criterion (1):
Criterion 1, NUREG-0737, Regulatory Guide 1.97, Rev. 3
The licensee shall have the capability to promptly obtain reactor coolant
samples and containment atmosphere samples.
The combined time allotted
for sampling and analysis should be 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or less from the time a
decision is made to take a sample.
Evaluation Results:
The licensee demonstrated the capability to obtain
reactor coolant samples and containment atmosphere samples and the
capability to sample and analyze those samples within three hours.
The licensee meets thi: criterion.
Criterion (2):
Criterion 2a, NUREG-0737, Regulatory Guide 1.97 Rev. 3
The licensee shall establish an onsite radiological analysis capability to
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provide within a three hour time frame, quantification of certain
radionuclides in the reactor coolan. and containment atmosphere that may
be indicators of the degree of cora damage (e.g., noble gases, iodines and
cesiums, and non-volatile radionuclides).
Evaluation Results:
The licansee provided an in-line sampling and
analysis facility which was demonstrated to be capable of providing,
within a three hour time frame, quantitative analysis of radionuclides in
reactor coolant samples and in containment atmosphere samples.
The
licensee employed the PWR Owners Group recommended procedure for
determining the degree of core damage in the event of a reactor accident.
The licensee meets this criterion.
Criterion (3):
Criterion 2b, NUREG-0737
The . licensee shall establish an onsite analysis capability to provide,
within a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time frame, quantification of hydrogen levels in the
containment atmosphere.
Evaluation Results:
The licensee has provided an onsite analysis
capability to provide, within a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time frame, an in-line quantitative
analysis facility for the determination of hydrogen levels in the
containment atmospnere. Calibration tecords indicated that the system was
capable of accurately quantifying concentrations of hydrogen gas in gas
samples containing predetermined concentrations of nydrogen gas.
The
inspector observed the sampling and analysis of containment atmosphere but
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since the containment atmosphere did not contain measurable hydrogen, the
analysis showed zero percent hydrogen.
Based on calibration data, the
inspector concluded that the system was adequate.
The licensee meets this criterion.
Criterion (4):
Criterion 2(c)(1) NUREG-0737
The licensee shall establish an onsite analysis capability to provide,
within a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time frame, quantification of dissolved gases (e.g. ,
hydrogen) in the reactor coolant.
Evaluation Results: The licensee has provided in-line sampling _ and
analysis capability for determination of dissolved hydrogen gas in reactor
coolant.
The licensee's hydrogen analysis system is based on gas
chromatography. The licensee demonstrated that the analytical results for
dissolved hydrogen in reactor coolant was available in less than three
hours.
The licensee meets this criterion.
Criterion (5):
Criterion 2(c)(2) and Criterion (7), NUREG-0737
The licensee shall establish an onsite analysis capability to provide
within a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time frame, quantification of boron concentration in
Evaluation Results:
The licensee has provided in-line sampling and
analytical capability for the determination of boron in reactor coolant
within a three hour time frame. Analysis was provided by an automatic
mannitol titration system.
Operation of the automatie boron analysis
system observed by the inspector produced results which correlated to the
normal reactor coolant boron analysis for the same time period to within
2.2 percent (PASS: 681 ppm; Normal Analysis:
696 ppm).
The licensee meets this criterion.
Criterion (6):
Criterion 2(c)(3) and Criterion (5), NUREG-0737
The licensee shall establish the ca dbility to provide chloride analysis
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for primary coolant.
If the plant's cooling water is seawater or brackish
water and if there is only a single barrier between the primary coolant
and the cooling water, the chloride analysis shall be provided within 24
hours of the time the sample was taken.
Cor all other cases, the licensee
shall provide f:r the analysis to be completed within 4 days (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />).
The chloride analysis, in either case above, does not have to be done
onsite.
Evaluation Results:
The licensee provided in-line chloride analysis for
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priuary coolant within a three hour time frame. The analysis was provided
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by means of an in-line ion chromatograph (IC).
The inspector noted that
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the chloride analysis value- was available in less than three hours.
Provisions was also made for grab sampling, with analysis available onsite
and for collecting a sample for shipment offsite for analysis, if needed.
-The licensee meets this criterion.
Criterion (7):
Criterion (3), NUREC-0737
Reactor coolant and containment atmosphere sampling shall not require an
isolated auxiliary system, such as the letdown system of a PWR, to be
placed in operation in order to use the sampling system.
Evaluation Results:
The design of the PASS for both reactor coolant and
containment atmosphere sampling did not require an isolated auxiliary
system, such as the letdown system or residual heat removal system, to be
placed in operation in order to use the sampling system. Certain sampling
line isolation valves were required to be activated from the main control
room in order to obtain samples; however, such valves were not systems of
the nature of the letdown system or the residual heat removal (RHR)
system. It was not the intent of the PASS criteria to prohibit actua. tion
of sampling line isolation valves during sampling under accident
conditions.
The licensee meets this criterion.
Criterion (8):
Criterion (4), NUREG-0737
The measurement of dissolved oxygen in primary coolant is recommended but
not mandatory.
For measurement of dissolved gases in primary coolant, the
measurement of either total dissolved gases or of hydrogen gas is
considered adequate.
Evaluation Results: The licensee provided a system for the measurement of
dissolved oxygen in primary coolant.
The system was an Orbisphere
detector for analysis of dissolved oxygen.
The inspector observed
operation of the dissolved oxygen system.
The Orbisphere results
indicated 11 ppb of dissulved oxygen in the PASS sample, while the
chemistry laboratory recorded a result of les; than 5 ppb.
than 500 ppb.
.+ 50 ppb at dissolved oxygen levels less
requires an accuracy of
The licensee's system for measurement of dissolved gases in primary
coolant utilizec an in-line gas chromatograph for determination of
See Criterion (4) and Criterion (13)a for further discussion.
The licensee meets this criterion.
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Criterion (9):
Criterion (6), NUREG-0737
The design basis fnr reactor coolant and containment atmosphere sampling
ano analysis systens must assure that it is possible to obtain and analyze
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a sample without radiation exposures to any individual exceeding 5 rem to
the whole body or.75 rem to the extremities.
Evaluation Results:
The design basis for the PASS for both reactor
coolant and containment atmosphere sampling and analysis was limitation of
radiation dose to operations under worst conditions to less than 5 rem to
the whole body and less than 75 rem to the extremities.
The inspector
reviewed Bechtel calculation package X6CDJ.08 and Vogtle Operating
Procedures 35620-C, Rev.1, and 35611-C, Rev. 3.
The review of selected
portions of the Bechtel evaluations and of procedures 35620-C and 35611-C
verified that calculated doses during system operation under worst design
basis conditions would be less than 5 rem to the whole body and 75 rem to
the extremities. The inspector reviewed the system installation and found
it to be consistent with the design.
The licensee meets this criterion.
Criterion (10):
Criterion (8), NUREG-0737
If in-line monitoring is used, the licensee shall provide backup sampling
through grab samples, and shall demonstrate the capability of analyzing
the grab samples. Established planning for analysis at offsite facilities
is acceptable.
Evaluation Results:
The licensee provided for grab sample capability for
all required sample analyses. An undiluted depressurized reactor coolant
sample can be collected in a transportable lead shield for processing and
analysis in an onsite laboratory. The sample can also be transferred to a
shipping container for transport to the Babcock and Wilcox f acility at
Lynchburg, Virginia, under pre-arranged agreement. The shipping container
for such a shipment woulc be procured under a owner's group agreement from
a pre-established facility and transported under a pre established
shipping contract.
A diluted reactor coolant grab sample can also be
obtained using a shielded syringe assembly which obtains a sample from the
sampling system through a septum and hyrodermic needle arrangement.
Containment atmosphere and stripped gas samples can also be obtained at
septum connections on the sampling panel.
Samples can be analyzed at an
onsite laboratory or can be shipped offsite for anaiysis.
The inspector observed grab samples being taken from the liquid and
gaseous septum connections on the sampling panel and grab samples taken by
a remotely operated device which injected a liquid reactor coolant sample
into a sample vial located in a shielded transport container. Liquid and
gaseous grab samples from all of the above locations were analyzed onsite
with acceptable results in accordance with accuracy requirements of
Criterion (13)
The licensee meets this criterion.
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Criterion (11):
Criterion (9)(a), NUREG-0737 and Regulatory Guide 1.97,
Rev. 3
Sampling and analysis capability for samples of primary coolant and of
containment atmosphere shall be provided for radioactivity concentrations
as follows:
Containment Atmosphere:
1 E-06 pCi/cc to 1 E+05 pCi/cc
Primary Coolant:
10 pCi/ml to 10 C1/ml (pressurized sample)
Evaluation Results:
The licensee provided for in-line sampling and
analysis of both diluted and undiluted reactor coolant and containment
atmosphere over the ranges prescribed by the above criteria.
Using a
1000:1 dilution and a small volume geometry for the detector of the gamma
spectrometry system, the vendor and licensee have calculated, on the basis
of calibration with undiluted standards, that the system would be capable
of evaluating reactor coolant samples with activity levels to 10 Ci/ml
(prior to dilution); however, it was noted that since the degassing which
takes place upstream of the detector is expected to remove more than 90%
of the total activity by removal of short-lived highly radioactive noble
gases, the licensee's design may actually be conservative by a factor of
ten or more.
The in-line analysis system for gamma spectrometry of
containment atmosphere was considered to be adequately designed and
fabricated. Calibration data on both the liquid gaseous channels of the
gamma spectrometer showed good correlation between expected or calculated
results and actual test data.
The licensee meets this criterion.
Criterion (12):
Criterion (9)(b), NUREG-0737
The design of the licensee's radiological and chemical sample analysis
facility should be such as to restrict radiation background levels,
attributable to post accident samples, to values such that the analyses
will provide results with small error factors. Acceptable errors should
not exceed a f actor of two.
Radiation reduction methods may include
shielding of samples and sample lines and controlled ventilation systems
exhausting to filtered release paths.
Evaluation Results: The licensee providea for the minimizing of radiation
levels at the in-line sampling and analytical f acility through provisions
for shielding, use of small diameter sampling lines, and provision for
flushing sampling lines after sampit procurement to minimize radiation
levels to both equipment and operators. The local sampling panel area is
ventilated by local exhaust intakes which exhaust to the plant vent by way
of charcoal adsorber beds and high efficiency particulate air (HEPA)
filtered systems.
The PASS can be remotely operated, folicwing initial
setup, from the remote control panel in a room adjacent to the Techrical
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Support Center (TSC).
If necessary, grab samples of reactor coolant and
containment atmosphere can be extracted at the local control panel and
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taken to alternative analytical facilities located in low radiation
background areas.
The licensee meets this criterion.
Criterion (13):
Criterion (10), NUREG-0737, Regulatory Guide 1.97, Rev. 3
Accuracy and range of analysis shall be adequate to provide pertinent data
to the operator in order to describe radiological and chemical status -of
Established criteria are as follows:
(a) Hydrogen or dissolved gases in primary coolant
Range:
0 to 2.000 cc/kg
Accuracy: 50 to 2,000 cc/kg: 1 10% desirable
20% acceptable
below 50 cc/kg:
5 cc/kg desirable
+
+ 10 cc/kg acceptable
(b) Chloride in primary coolant
Range:
0 to 20 ppm
Accuracy: 1 10% 0.5 to 20 ppm Cl
+ 50 ppb for C1 - less than 50 ppb
(c) Boron in primary coolant
Range:
0 - 6,000 ppm
Accuracy: + 5% @ 1,000 to 6,000 ppm
2 50 ppm @ 0 to 1,000 ppm
(d) Dissolved oxygen in primary coolant (not a requirement)
Range:
0 - 20 ppm
Accuracy: 1 10% @ 0.5 to 20 ppm
+ 50 ppb @ 0 to 500 ppb
(e) pH in Primary Coolant
Range:
1 - 13 pH units
Accuracy: 1 0.3 pH unit @ 5 to 9
+ 0.5 pH unit @ 1-5 and 9-13
Evaluation Results:
The licensee had provided analytical equipment for
in-line identification and measurement of all of the above items in the
ranges and accuracies specified.
The inspector cbserved as measurements were taken with the in-line
instrumentation ano, in some cases, by anal 3
s of grab samples.
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(a) The measurement of hydrogen in primary coolant using the in-line gas
chromatograph produced results which were significantly below those
produced in the normal sample analyses of primary coolant.
The
licensee was not able to demonstrate the required accuracy.
Investigation by licensee staff into the underlying cause appeared to
indicate the presence of a vacuum leak in the gas evacuation chamber
of the gas chromatograph.
The licensee was not able to resolve the
problem as of the end date of this inspection.
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(b) Chloride in primary coolant was analyzed on the in-line liquid ion
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chromatograph of the PASS.
No chloride was detected in either the
PASS analysis or in the normal reactor coolant sample analysis.
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Calit ration data for chlorides showed sati sf actory correlation
between known value and IC readout.
(c) Boron in primary coolant was analyzed using the in-line automatic
titration system using the mannitol titration procedure.
The value
of 681.1 ppm attained on the PASS in-line analysis system compared
within + 3% of the value reported for the concurrent normal reactor
coolant sample analysis for boron.
(d) Dissolved oxygen in primary coolant was analyzed using the in-line
Orbisphere detector.
The PASS analysis indicated 11 ppb while the
normal reactor coolant sample analysis indicated less than 5 ppb.
The PASS value was well within the prescribed accuracy of + 50 ppb at
0 to 500 ppb concentration.
(e) pH in primary coolant was measured on the PASS in-line pH meter at a
pH of 6.3.
The normal reactor coolant sample analysis for the same
time period indicated a pH of 6.4.
This was within the prescribed
accuracy of + 0.3 pH unit in the range of 5 to 9 pH units.
With the exception of the in-line analysis of dissolved hydrogen in
primary coolant, the licensee met all of the sub-criteria of this
criterion.
Licensee records indicated that the dissolved hydrogen
analysis system had functioned properly prior to this inspection.
The licensee meets this criterion, with the exceptions noted.
Criterion (14):
Criterion (11), NUREG-0737
Provisions should be made for purging sample lines, for reducing plateout
in sample lines, for minimizing sample loss or distortion, for preventing
blockage of sample lines by loose material in the reactor coolant system
or containment, for appropriate disposal of samples, and for flow
restriction to limit the coolant loss f rom a rt,pture of the sample line.
The ventilation exhaust from the sample station should be filtered at some
point through charcoal absorbers and high efficiency particuiate air
(HEPA) filters.
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The residues of liquid sample collection should be returned to containment
or to a closed system. Purges of liquid or gaseous sample lines for the
purpose of assuring a fresh representative sample should be returned to
containment, preferably to the system of origin.
Purges of sample lines
af ter sample collection should be returned to containment (to original
system, to the containment sump in the case of liquids, or to the
containment atmosphere in the case of containment atmosphere samples).
Evaluation Results:
The licensee made provisions for the purging of
liquid and gaseous sampling lines to assure that representative samples
were delivered to to the points of sampling and analyses.
Further, the
licensee made provisions for the purging of liquid and gaseous sampling
lines af ter sampling, with distilled water and gaseous nitrogen to reduce
the potential for excessive radiation levels and to reduce background at
the in-line gamma spectrometer. The licensee also provided for diverting
purge materials back to containment in the event of an accident, with
liquids going to the containment sump and gases to containment atmosphere.
Under normal operating conditions, .for example, during tests and
calibration of PASS components, liquid wastes would go to the normal
liquid radwaste system and gaseous wastes would go to a filtered and
monitored gaseous discharge stack.
The inspector verified that these
provisions had been installed.
The licensee meets this criteria.
Criterion (15):
The licensee shall have a formalized training program, written lesson
plans, and documented hands-on training.
An adequate number of licensee
staff members should be qualified to provide operation of the equipment
under protracted accident conditions.
Evaluation Results:
The inspector reviewed the formal PASS training
program during previous inspections (50-424/87-34 and 50-424/87-09).
The
training program was established as a formal prog am, written lesson plans
had been prepared and approved, and all training, including "hands-on"
operation of the system, had been documented.
The number of personnel
trained on the PASS appeared to be adequate.
Provision was made for
annual re-training and qualification.
The licensee meets this criterion.
Criterion (16):
The licensee shall have operating procedures that have been prepared,
reviewed, and approved in accordance with station requirements.
Evaluation Results:
The inspector reviewed PASS operating, tracking,
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surveillance,
and calibration procedures during prior inspections,
50-424/87-09, 50-424/86-119, and 50-424/87-137.
The procedures appeared
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to be adequate and had been reviewed and approved by appropriate
management in accordance with Technical Specification requirements.
The licensee meets this criterion.
Criterion (17):
The licensee shall have a formal acceptance test program for the
equipment, appropriate calibration and recalibration requirements, and a
periodic performance test for each analytical test required for the
equipment.
Evaluation Results:
The inspector reviewed the licensee's program for
formal acceptance and preoperational tests of the PASS during prior
inspection 50-424/87-09.
The
formal programs for calibration and
surveillance, including periodic performance tests for each analytical
test required for the equipment, were reviewed by the inspector.
The acceptance and preoperational tests of the PASS appeared to have been
completed satisfactorily;
however,
during review of the periodic
calibration, recalibration, and periodic performance tests for each
analytical test required for the PASS, it was observed that certain items
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had not been completeo in accordance with established schedules.
Technical Specification 6.7.1.b requires the licensee to implement
established procedures, which include those established for the PASS.
A
number of PASS procedures for PASS components or sub-system calibration
and recalibration required performance at monthly intervals or not to
exceed 45 days.
Several instances were identified in which the required
tests or calibrations had not been performed within the specified time
limitations of the procedure.
In three of those instances, the specified
time limitations had been exceeded by from 17 to 49 days.
This was
identifiec in Section 9 in this report as a Technical Specification
violation for failure to follow procedures.
Prior to the end of the
inspection, the licensee had initiated steps to prevent a recurrence.
Subject to the resolution of the above-noted violation, the licensee meets
this criterion.