ML20148R969

Insp Rept 50-424/87-68 on 871207-11.Violation Noted.Major Areas inspected:post-accident Sampling Sys Evaluation, Investigation of Technical Aspects of Allegations & Followup on Previously Identified Items

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: ML20148R969
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.: NPF-61

Inspection cond d: Dec m er 7-11, 1987

Inspector: w/ /'/7#

Date Signed

P.'G.-Stodda'r P

Approved by: ~

Obb.jd / //y /D

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.

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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

NUREG-0737 Meets all Meet All o'

Criteria of Criteria Criteria Reasons

1 X

2 X

3 X

4 X Hydrogen analysis

of reactor coolant

or stripped gas was

outside of accuracy

guidelines

5 X

6 x

7 X

. 8 X

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9 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

l necessary procedures and to validate those procedures through operation of

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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.

'at intervals.not to exceed 45 days.

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Technical Specification 6.7.1.b req ui're s the licensee to implement

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. '

(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 i

selected calculations. The documentation appeared to be adequate and

satisfactorily addressed the principal points of concern in the matters of

shielding and dose calculation.

l .No violations or deviations were identified.

i 11. PASS Design Requirements

NUREG-0737 Criterion 3 (II.B.3: PASS) specifies that reactor coolant and

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containment atmosphere sampling CJring accident conditions shall not

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.

12 .' 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

licensee was demonstrating an alternative or backup method f or obtaining a

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"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

sample was taken and analyzed within the prescribed time.

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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 i

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 - Reactor Coolant

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

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I-131  !-- -----

1.15E-04{0.56E-04

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I-1T ' 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 i' nspector conducted a review of circumstances surrounding Allegation

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;

l 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

Bridge and Iron (CB&I). 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

i been involved in mechanical work in the Interim Radwaste Facility in

l March 1987 -- the period concerned in the allegation -- further

investigation into this allegation was not considered within the

l scope of the inspector's assignment. This matter was referred to the

l 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: PWR

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 .

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

reactor coolant.

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 rdbility to provide chloride analysis

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

l priuary coolant within a three hour time frame. The analysis was provided

by means of an in-line ion chromatograph (IC).

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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. NUREG-0737

requires an accuracy of .+ 50 ppb at dissolved oxygen levels less

than 500 ppb.

The licensee's system for measurement of dissolved gases in primary

coolant utilizec an in-line gas chromatograph for determination of

hydrogen. 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

l 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

the reactor coolant systems.

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

chromatograph of the PASS. No chloride was detected in either the

PASS analysis or in the normal reactor coolant sample analysis. 3

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,

l 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 '.

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.