ML20151J100
| ML20151J100 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/11/1984 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151J101 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 5211-84-2105, NUDOCS 8406260019 | |
| Download: ML20151J100 (14) | |
Text
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GPU Nuclear Corporation Ng gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2388 Writer's Direct Dial Number:
May 11, 1984 5211-84-2105 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 (Post Accident Sampling and Monitoring)
Our letter of March 8,1984 provided the list of actions GPUN is pursuing in regard to post accident sampling along with commitment dates targeted for completion of each item. Responses to certain of those items were shown to require additional submittals.
This letter transmits GPUN's response to several outstanding items and indicates those items which have been completed since our last submittal. is an update to our list of outstanding items. Attachment 2 (GPUN Response) and Attachment 3 (TDR-494) provide responses to several of these items as indicated in Attachment 1.
Those items for which responses have been provided are not included in this submittal.
Sincerely, U D. Huki 1 Director, TMI-l HDH:RK/kls attachments cc:
R. Conte 8406260019 840608 PDR ADOCK 05000289 G
PDR 4
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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52il-84-2105 Attachment i Page 1 POST ACCIDENT SNFLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR (PUN Targeted item Action Completion No.
Inspection Report item No.
(PUN Action Date (Note 1) 64-03-01 RCS SMPLING 1.a Provide the capability to obtain an RCS I.a.1 Revise the EPIP involved in taking the Post Accident
- Complete, sample under all accident conditions and RCS sample (l004.15) to include, as an option, the (Note 2) 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.3 Complete modification of post accident sampling 10/01/84 system to tie in decay heat sample lines elf h the shielded reactor coolant sample line in the nuclear sampiing room.
1.a.4 Revise procedure to include taking a post accident
- Complete, sample from the decay heat system in the present (Note 2) 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.
l.a.5 Revise TDR 494 to include additional exposure
- Complete, considerations for taking a decay heat sample See af ter 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.
( Section 111.1.)
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5311-84-2003 Attachment I Page 2 POST ACCIDENT SMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR GPUN item Targeted Action Completion No.
Inspection Heport item ho.
CPUN Action Date (Note 1) is4-03-02 CAS 2.a M>dif y CAS to permit sampli ng af ter 2.a.1 Revise procedures to enable override of containment
- Complete, containment isolation. Provide tempera-Isolation above 30#.
(t*>te 2) ture and pressure indications at the gas sample bomb. Develop procedures to 2.a.2 Review the dusign of the Containment Atmosphere Complete.
quantify the sample including temperature Sampling System and provide a schedule for completion See arvi pressure corrections, of any modifications. Address the need for:
l} Additforal heat tracing and/or insulation
- 2) Elimination of the flowneter
- 3) Elevation of the sample bomb
- 4) Shielding the sample bomb 2.a.3 Provide a uriteup to describe operation of the Complete.
Containment Atmosphere Sampling System including See any modifications.
2.a.4 Mxfify procedures to quantif y the sample including 06/01/84 temperature and pressure corrections.
2.a 5 Complete modification of Containment Atmosphere 10/01/84 Sampling System as described in GPUN response to item 2.a.2.
2.b Evaluate sompte rupresentativeness in
- 2. b. !
Describe the design of the Contalrvnent Atmosphere
- Complete, regard to possible condensation and lodine Sampling System to obtain a representative sample See plateout in the gas sample bomb.
In regard to possible condensation and Iodine plateout in the gas sample bomb.
(Section Ill.H.)
2.c' Perform error analysis to estimate the 2.c. I Describe sample transfers, perform error analysis Complete.
sample losses attributed to sample and describe accep,tability of the Containment See transfers called for in the procedures.
Atmosphere Sampling System equipment.
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a 5311-84-2105 Attachment i Page 3 P03T ACCIDENT SAMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR CPUN Targeted Itan Action Completion No.
Inspection Report item No.
CPUN Action Date (Note 1) 2.c.2 investigate the need for special precautions which
- Complete, might need to be taken to prevent unnecessary f ailure See of the syringe used in obtaining the containment atmosphore sample and incorporate any necessary procedural changes.
84-03-03 OTHER 3.c Establish a formal preventive maintenance 3.c I Describe formal preventive maintenance and survell-Complete.
and surveillance program for the CAS lance programs for the Containment Atmosphere See sy stem.
Sampling System, and provide a schedule for Implementation.
3.c.2 Incorporate procedural changes required to implement Complete.
the progryn described in 3.c l.
(Note 2) 3.d Address the dose received ty personnel 3.d.1 Develop a revised process for collecting and trans-Complete.
transporting the sample to the counting porting the sample using a portable pig, procedur-(Note 2)
- room, alize the process, and perform time and motion studies. (See 3.e.1 and 4.2.1 )
3.d.2 Revise TDR 529 to include the dose received by 06/01/84*
personnel transporting the sample to the counting room (See 4.2.11.
Consider dose contribution from hydrogen recombiners.
3.e Address the possibility of high airborne 3.e.1 Revise the procedure to require a respirator to Complete.
radioactivity shlle collectity the CAS be morn.
(Note 2) and the need to usar a respirator.
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5311-84-2105 Attactinent 1 Page 4
~
POST ACCIDENT SAWLlNG AND MONITORitG (lR 84-03)
OUTSTANDING ITEMS IR CPUN Targeted Item Action CompietIon No.
Inspection Report Item No.
(PUN Action Date (Note 1) 84-03-04 SHIELDING 4.1 Revise snielding study (RCS sampling) 4.1.a Perform dose rate cales and revise TDR 494 to Complete.
to include the following contributors:
Include contributors listed in 4.1 for as-built See a - Sink drain trap and drain line.
configuration and specify source terms.
b - Undiluted coolant in the sink.
c - Scattered radiation.
4.1.c Revise procedure to verify in-flow of air into the Complete.
d - Unshielded auxiliary lines.
sample hood prior to initiation of RCS sample flow (Note 2) e - Residual contamination during in order to minimize airborne radioactivity subsoquent sample attempts.
originating from the sink. The determination of f - Airborne radioactivity originating air flow will be based on visually ctecking that from sink.
ribbons attached to the bottom of the hood door are pulled into the hood.
4.1.d Revise EPIP 1004.15 to require Radiological Assessment Complete.
Coordinator and Emergency Director concurrence (Note 2) prior to initiating flow through auxillary systems which might introduce high activity water through unshielded auxillary lines located in the chemistry lab / sample sink area.
4.1.e Provide temporary shielding for the sample sink drain 06/01/84 line and revise procedure to verify shielding is In place prior to initiation of RCS sample flow.
4.2 Conduct a shielding study on the as-built 4.2.1 Revision to TDR 529 dewribed in 3.d.2 mill include 06/01/84*
system for collecting and transportleg shielding studies for collecting and transporting the CAS.
the Containmeni Atmosphere Sample (see 3.d.2),
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52il-84-2l05 Page 5 POST ACCIDENT SMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR (PUN Targeted item Action Completion No.
Inspection Report Item No.
GPUN Action Date (Note 1) 64-03-05 ANALYTICAL CAPABILITY 5.a Develop procedures for use of 5.a.2 Complete the necessary procedural modifications for Complete.
fluoroborate probe and pH miniprobe.
performing the Chloride, Doron, and pH analysis Note 2 using permanent equipment dedicated for use at TMI-l.
(Lowr minimum range for Baron analysis is 500 ppm.)
5.a.3 Resolve the problem regarding fluoroborate analysis 07/01/84 for Boron concentrations below 500 ppm or justify a lower minimum range for Doron analysis of 500 ppm.
5.b Provide the results of demonstration of
- 5. b. I Perform demonstrations onsite using TMI-I procedures
- Complete, chemical analysis capability for to confirm the results trcnsmitted to tRR on 2/29/84 Chloride, Baron, and pH using the in preparation for inspector followup demonstrations, intended instrumentation and procedures.
5.c Revise procedures to address analysis of 5.c ?
3 rov i de a complete response to 5.c.
06/0l/84*
fission gases stripped from the RCS sample for determining gross activity.
047iA em.
5211-84-2l05 Attachment i Page 6 POST ACCIDENT SAWLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS IR (PUN Targeted item Action Completion No.
Inspection Report item No.
(PUN Action Date (Note 1) 84-03-06 NOBLE GAS EFFLUENT MONITOR 6.a Provide conversion f actors from CPM to 6.a.2 Complete the modifications to the computer program 06/01/84 pcl/cc for monitor readouts.
for of f site dose calculations as described in GPUN response of March 8, 1984 84-03-07 SAW LING AND ANALYSIS OF PLANT
. EFFLUENTS (MM'-5) 7.a Develop procedures for collection of 7.a.1 investigate the collection, handling, and analysis 07/01/84 representative plant ef fluent samples of high dose rate samples as described in 7.a, make including provisions for handling and the necessary procedural modifications, and perform analyzing tilgh dose rate samples, time and motion studies for the resultant process.
A 7.e.2 Provide dose calculations based on the time and motion 07/0l/84
- studies for the process which results from 7.a.l.
84-03-08 SA W LING AND ANALYSIS OF PLANT EFFLUENTS (MAP-5) 8.a Install snields around all MAP-S 8.a.1 Complete installation of shields described in 8.a.
06/01/84 cartridges.
8.b Document follomup action taken on 8.b.I Document followup action taken on IEN-82-49 In 06/01/84 IEN-82-49.
regard to MAP-5, e.g., provide flow meter correction curves and ccznplete the necessary procedural modifications.
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.a 5211-84-2105' Attachment i Page 7 POST ACCIDENT S# FLING AND MONITORING (IR 84-03) 00TSTAND1NG ITEMS
~.
IR PUN Targeted item Action Completion No. -
Inspection Report item Pb.
@UN Action Date (Note 1)
Other PASS Commitments 9.a ~
Complete installation of seismic rack for bottled 06/01/84 af r to serve.as backup air for eductor In the Containment Atmosphere Sampling System.
9.b in order to insure that suf ficient volume remains Complete.
In the makeup tank to receive the volume of reactor (Note 2) coolant sample which will be discharged, revise procedures to specify a 15 minute purge time and add a prerequisite to ensure a suf ficient volume remains available in the makeup tank as freeboard.
9.c Determine the ef fect on Aux. Bldg. habitability
- Complete, of the sink drain containing reactor coolant sample See from the accident being flushed to the sump (consider both the drains from the liquid and stripped gas (Section samples).
Ill.G.)
9.d Verify the adequacy of the existing calculational
- Complete, method for a'nalysis of the RCS gas sample.
(Note 2) 9.e Verify the accuracy of the pressure gauge used for
- Complete, collection of the RCS gas sample.
See 9.f Perform exposure arialysis for obtaining a noble gas
- Complete, sample at RMA-5 under post accident conditions.
See NOTE I - Completion dates which show an asterisk indicate that an addi'tional submittal to t#tC is required.
NOTE 2 - This procedure is available at the site for inspection.
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r 5211-84-2105 Page 1 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
2.a.1 Sampling above 30 psig is within the current capability of the Containment Atmosphere Post Accident Sampling System (CATPASS).
Therefore, EP 1004.31 has been revised to delete the 30 psig sampling limitation.
2.a.2 The Containment Atmospheric Post Accident Sampling System (CATPASS) will be modified to improve its operation in order to obtain a more representative sample. Basically, this will be accomplished by minimizing changes in flow rate and temperature. Modification of the CATPASS will include the following changes (See Figure 1):
1.
Insulation will be added to all tubing at the sample station to minimize heat loss.
- 11. The sample bomb will be replaced by a septum. The sample will be obtained from the septum and transported in a syringe.
Removal of the sample bomb will eliminate a change in velocity of the sample stream due to the change in cross sectional area and will reduce the internal surface area of the system at the sample point. This will reduce the possibility of condensation and plateout of iodine, iii. The sample point (septum) will be located as close as possible to the point where heat tracing ends in order to minimize heat loss at the sample point. The septum will be orientated in such a manner as to prevent any condensation which might be present in the tubing lines from entering the sample. Pressure tests on the septum will be required in accordance with the CATPASS System Design Description to evaluate leakage characteristics ano to establish the pressure rating and replacement requirements for the septum.
iv. The following will be eliminated from the system:
solenoid valves (CH-V12 & 13), pressure reducing valve (CM-V25), pressure switches (PS-998 & 999), pressure indicator (PI-997), flow indicator (FI-837) and isolation valves (CMV-11, 34, 35, 36 &
37). This will eliminate heat sinks and points of possible condensation.
v.
Porcelain insulators will be added to the tubing supports to minimize heat loss through the supports, vi. A condensate drip leg will be added downstream of the sample point to remove any' condensation which might be present, j
1
5211-84-2105 Page 2 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
GPUN Action No. 2.a.5 has been added to Attachment 1 to address this modification.
2.a.3 The following is a description of the operation of the CATPASS on completion of the modifications described in 2.a.2:
Post accident containment atmosphere will be sampled using the existing sample and return lines for radiation monitor (RM-A2).
Three-way valves will valve out RM-A2 and direct the sample through heat traced tubing lines to the sampling station. Control of these valves will be from the local control panel. An eductor pump, using either plant instrument air or bottled air / nitrogen, will provide the motive force for obtaining the sample. Instrument air or bottled air / nitrogen will also be used for purge and pressure test.
The sample station will be provided with a temperature indicator, high range pressure gauge, low range pressure gauge, septum, condensate drip leg, and drain valves. The pressure gauges and septum will each be provided with isolation valves.
Sample flow will be directed from recirculation to the sample station by three-way valves controlled from the local control panel. Sample temperature and flow indication will be provided at the local control panel. When flow to the sample station has been established for sufficient time to ensure a representative sample, the sample will be withdrawn from the septtrn using a syringe and transported to the laboratory for analysis.
2.c.1 The following steps describe the sample transfer evolution by a and technician from time of sampling to time of sample preparation.
2.c.2 1.
Withdraw a 3 cc sample from the Catpass bomb using a 5 cc Pressure-Lok Series A-2 syringe.
2.
After sampling, lock valve on syringe will be depressed and the needle removed from syringe body.
3.
Place the needle and syringe body into the shielded syringe carrier.
4.
After Catpass system has been secured, transport the syringe carrier to the sample preparation area (Radio Chem Lab).
The syringe which would be used to obtain a post accident sample of the containment atmosphere is a 5 cc Pressure-Lok Series A-2 syringe manufactured by Precision Sampling Corporation.
5211-84-2105 Page 3 POST ACCIDENT SAMPLING AND MONITORING (IR 84-03)
OUTSTANDING ITEMS GPUN ACTION GPUN RESPONSE NO.
This syringe maintains the integrity of the sample through a pushbutton valve assembly which permits storage of liquid or gaseous samples under vacuum or elevated pressures up to 250 psig.
The capability exists for prepressurization of the sample prior to transfers or chromatograph analysis if desired. Vacuum leakage rate is less than 9.3 x 10-5% per hour, or less than 2.8 x 10-3 ul/hr for a 3cc sample.
The Pressure-Lok syringe contains a low dead volume. When the plunger is fully depressed practically no compressible dead volume remains.
A positive rear flange plunger stop prevents the plunger from blowing out of barrel at elevated pressures, protecting against accident sample loss or possible operator injury.
The plunger tip, fabricated of virgin Teflon, is stress formed to stay leak tight and self lubricating for smooth operation.
Based upon the above specifications and the expected pressure of a post accident containment atmosphere sample (< 50 psi), GPUN does not anticipate failure of the Pressure-Lok syringe to be a problem.
Special procedural precautions do not appear to be needed. Syringes of this type will be placed into the emergency equipment cabinet and inventoried quarterly per AP 1053. Procedure changes will be made specifying the use and operation of the Pressure-Lok Series A-2 syringe by name to avoid the use of a lower quality syringe.
3.c.1 Functional test and leak check of the Containment Atmosphere Post Accident Sampling System (CATPASS) are included in the TMI-l preventive maintenance program (procedure IC-132).
Instrument calibration is included in MTX-168. Modifications to the CATPASS may result in changes to the maintenance program as necessary.
Maintenance procedures are available at the site for inspection.
9.e GPUN has reviewed the accuracy of the pressure gauge for the RCS gas sample collection. Based on our calculations, the error introduced by the pressure gauge would result in an uncertainty of + 1.4% in the determination of hydrogen or total gas. Since that is a small portion of the 10% uncertainty estimated for this analysis, the existing gauge is considered to be acceptable. - This calculation will be maintained on file at the site for review.
- ~ _ -.
52_1-84-2105 Page 4 f
POST ACCIDENT SAMPLING Ato MONITORING (IR 84-03)
OUTSTANDING ITEMS GPUN ACTION GPLN RESPONSE 4
NO.
9.f GPUN has performed an exposure analysis for obtaining a noble gas sample at RMA-5 under post accident conditions.
A time and motion study was performed. Those times were increased by 3
25% to account for the encumbrance of a breathing apparatus.
The computer cooe ISOSHLD II was used to evaluate the exposure rate.
l A source term of 100 uCi/cc from RMA-5 was utilized. This assunption was based on the maximum design basis given in Table II.F.1-1 of NUREG-0737. In order to evaluate the source term,100 percent of nobel gases and one tenth of the 25 percent of iodine core inventory for 310 effective full power days at rated power level of 2535 MWT, were normalized to 100 pCi/cc.
Two cases were analyzed:
(1) using a marinneli beaker to carry the sample and (2) using the 25 cc bulb. Total exposure results for the two cases analyzed were as follows:
Whole Body (Rem)
Extremities (Rem)
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marinnell beaker 5.5 (-2) 9.9 (-2) 25 cc bulb 2.5 (-2) 8.5 (-3) i e
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021902 tuclear Document Release Form (Refer to EMP-008)
May 10, 1984 Date Page 1 of 1
Release Action To: Distribution O Review / Comment a Construction a As-Builts a Procurement (5 Record O Operations / Maintenance O Hold Construction Originator Tae Y.
Bvoun Home Base 5412 Tel ??l2 Unit m'n - 1 Budget Activity #
125403 WO/SO # 5400-41711 List of Released items Company Document No.
Sheet Rev.
Title GPU TDR 494 41 2
" Post-Accident Sampling Radiological Analysis" c
Speciat instructions This TDR closes Action Items: LIO A/I #84-9091, 84-9102, 84-9106, and 84-9115.
References / Attachments Approve Date CC SEE ATTACHMENT s