L-82-525, Forwards Responses to NRC Re NUREG-0737,Item II.B.3, Post-Accident Sampling Sys. W/Three Oversize Drawings.Aperture Cards Are Available in PDR
| ML17301A015 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/06/1982 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17213A882 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM L-82-525, NUDOCS 8212150068 | |
| Download: ML17301A015 (18) | |
Text
REGULAT INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION N"R:8212150068 DOCgDATE: 82/12/06 NOTARIZED:
NO FACIL:50-335 St. Lucie Planti Unit 1< Florida Power L Light Co, AUTHNAME AUTHOR AFFILIATION UHRIGgR ~ E, Florida Power L Light Co, RECIP, NAME RECIPIENT AFFILIATION
,CLARKrR ~ A, Operating Reactors Branch 3
SUBJECT:
Forwards responses to NRC 820713 ltr re NUREG-0737i Item IIl8 3p
'Post-Accident Sampling Sys," N/three over size drawin s,Apertur cards are available in PDR, II DISTRIBUTION C
~
46 C PIES REC IVED LTR ENCL SIZE ~
TITLE:
OR Submittal:
TMI Action Plan Rgmt NUREG-0737 8
NUREG-0660 NOTE s:
64c.~k graf jgt ID CODE/NAME LTTR ENCL ID CODE!NAME LTTR ENCL NRR ORB3 BC 01 7
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7 DOCKET 05000335 INTERVAL; ELD/HDS2 IE/DEP EPDS NRR/DHFS/DEPY29 NRR/DL/ADL 16 NRR/DL/ADSA 17 NRR/DSI/ADRP 26 NRR/DSI/AEB NRR/DPT DIR 30 RGN2 EXTERNAL: ACRS 34 INPOiJ ~ STARNES NRC PDR 02 NTIS 0
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FLORIDAPOWER & LIGHTCOMPANY December 6, 1982 L-82-525 Office of Nuclear Reactor Regulation Attenti on:
Robert A. Cl ark, Chi ef Operating Reactors Branch g3 Division of Licensing U.S.
Nuclear Regulatory Commission Washington, O.C.
20555
Dear Mr. Clark:
Re:
St. Lucie Unit 1
Oocket No. 50-335 POST-TMI Requi rements NUREG-0737 ITEM II.B.3 Post Accident Sampling System Attached is our response to your letter of July 13, 1982, in which you r equested information about the St. Lucie Unit 1 Post Accident Sampling Systen.
The response addresses each "criterion" specified by NIJREG-0737.
'4Ie trust that the enclosed information will aid the NRC staff in t he i r pos t impl erne ntati on rev i ew.
Very truly yours, R
ert E. Uhrig Vice President Advanced System and Technology REU/PKG/js Attachments cc:
Mr. James P. O'Reil ly, Region II Harold F.
Rei s, Esquire 82121500h8 821206 PDR ADOCK 05000335 P
PDR PEOPLE... SERVING PEOPLE
Attachment 1
ST.
LUCIE UNIT 1
POST-TMI REQU IR EME NTS NUREG-0737 ITEM II. 8.3 POST ACCIDENT SAMPLING SYSTEM The St. Luci e Unit 1
FSAR section 9.3.7 which contains the Post Accident Sampling System (PASS) design
- bases, system description and component desc ription is enclosed in attachment 2 to aid you in your revi ew.
Also enclosed to aid you in your review are the following St. Lucie drawi ngs:
a.
Hydrogen Sampling System Flow Diagram b..
Hydrogen Analyzer P 5 ID c.
Post Accident Sampling System Flow Diagram Criterion:
RESPONSE
(1)
The licensee shall have the capability to promptly obtain reactor =coolant samples and contaionent 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
sampl e.
'The St. Lucie Unit 1
PASS is designed to take and analyze reactor coolant samples within three (3) hours from the time a decision is made to take a sample.
The contaiment, hydrogen sampling system will also take and analyze contaimoent atmosphere samples within three (3) hours.
All aspects of how these criteria were met were witnessed first hand by NRC personnel who observed the St. Lucie chai stry department perform PASS operations during the February 1982 Emergency Drill.
Only two functions were not performed at that time.
a.
A containment grab sample for activity which is approximately a 10-minute remote startup of our H2 analyzers through an installed sample cylinder.
The sample cylinder is cart mounted for ease of transport.
(See P 5 ID of Hydrogen Analyzer).
b.
Use of backup power sources was not demonstrated.
The instrument portion of the PASS is automatically picked up on emergency diesel loading>
Power to the PASS System solenoid valves and pumping systems is manually loaded after the auto sequence.
Criterion:
(2)
The licensee shall establish an onsite radiological and chemical analysis capability to provide, within three-hour time frame established above, quantification of the following:
(a) certain radi onuclides in the reactor coolant and containment atmosphere that may be indicators of the degree of core damage (e.g.,
noble gases; iodines and
- cesiums, and non-volatile isotopes);
(b)'ydrogen levels in the contairrnent atmosphere;
RESPONSE
(c) dissolved gases (e.g.,
H2), chloride (time allotted for analysis subject to discussion below),
and boron concentration of liquids.
(d)
Alternatively, have in-line monitoring capabilities to perform all or part of the above analyses.
The St. Lucie Unit I PASS System provides in-line monitoring for pH, dissolved oxygen and hydrogen.
The PASS System also provides the capability to collect dil.uted or undiluted liquid and gaseous grab samples that can be transported to the radio-chemical 1 aboratory for'oron, chl oride, and/or radionuclide analyses.
If possible the St. Ludie Unit I radio-chemical laboratory would be used.
In the event that the normal laboratory could not be used, a remote laboratory would be established as provided in St. Lucie Unit No. I Chemistry Procedure No. C-ill, "Establishing Remote Analysis Laboratory, Counting Laboratory and Counting Procedure for Accident Samples".
In addition, in-line redundant monitoring of contairment hydrogen is provided per the requirements of NUREG-0737 ITEN II.F.1.6.
This system is shown in the P 5 ID provided with the attached FSAR Secti on.
Combustion Engineering, Inc. and Exxon Nuclear Company, Inc. have been requested to develop guidelines to relate reactor coolant and
- contaireent atmosphere radionuclide concentration to core damage.
Criterion:
(3)
Reactor coolant and containment atmosphere sampling during post accident conditions shal 1 not require an isolated auxiliary system [e.g., the letdown system, reactor water cleanup system (R'WCUS)] to be placed in operation in order to use the sampling system.
RESPONSE
Criterion:
RESPONSE
Criterion:
The system P
5 I'D contained in the enclosed FSAR section clearly demonstrates that PASS and Containment Hydrogen Sampling System samples can be taken from each sample source and recirculated back to containment without the use of an isolated auxili ary system.
Any valves that would shut on a containment isolation signal have been given remote (frcm control roan) override capability.
(4)
Pressurized reactor coolant samples are not required if the licensee can quantify the amount of dissolved gases with unpressurized reactor coolant samples.
The measurement of either total.dissolved gases or H~ gas in reactor coolant samples is considered adequate.
Aeasuring the 02 concentration is recaomended, but is not mandatory.
As discussed in our response to Criterion (2), both grab and in-line H2 and total gas measurements can be made.
Details of this are provided in Sh. Lucie Unit 1 Chemistry Procedure No. 1-C-112 "Operation and Calibration of the Milton Roy Post-Accident Sampling System".
The attached PASS flow diagram shows that in-line dissolved oxygen can be read during-any system recirculation lineup.
(5)
The time for a chloride analysis to be performed is dependent upon two factors:
(a) if the plant's coolant water is seawater or brackish water and (b) if there is only a single barrier between primary containment systems and the cooling water.
Under both of the above conditions the licensee shall provide for a chloride analysis within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the sample being taken.
For all other cases, the licensee shall provide for the analysis to be completed within 4 days.
The chloride anal ys i s does not have to be done ons ite.
RESPONSE
Criterion:
Primary system component cooling at St. Lucie Unit 1 is provided by the Component Cooling Water System.
The Secondary Component Cooling Water System provided two barriers against in-leakage from the plant's seawater systems.
Consequently the criteria for a 4-day sample are afforded.
. As shown in the attached PASS flow diagram and discussed in the attached FSAR, the system has the capability for diluted and undiluted samples.
Diluted to a level of 1 to 50, Chloride sensitivity is.002 ppm.
Dissolved oxygen capabilities are discussed in our response to Criterion (4).
(6)
The design basis for plant equipment for reactor coolant and contaireent atmosphere sampling and analysis must assume that it is possible to obtain and analyze a sample without radiation exposures to any individual exceeding the criteria
RESPONSE
The scenario of the drill assumed a design basis double ended pipe rupture.
After 20 minutes, the'lant would be on containment recirculation.
Reactor coolant would be pumped from the containment Sump through the shutdown cooling heat exchangers and containment spray pumps.
Reactor Coolant System gross activity was assumed to be.5 Ci/cc and Reactor Contaianent Building air activity was assumed to be 10 millicuries/cc.
For training purposes, the drill was run in four distinct phases:
Remote lab RCS sample Contai nment sample Plant vent and steam dump radiation monitors.
The drill (whi ch was witnessed by the NRC Resident Inspector) was performed satisfactorily.
The maximum projected dose received was due to obtaining the RCS sample.
All projected doses were far below the three (3)
REM W.B. limit estabi shed at that time.
a 0 b.
c ~
d.
It should be noted that this drill was performed prior to the instal lation of the PASS.
Since the PASS System reduces exposure time and has added additional shielding for all analyses, doses using the current system will be within the GDC-19 guidelines.
of GDC 19 ('ppendix A, 10 CFR Part
- 50) (i.e.,
5 rem whole
- body, 75 rem extremities).
(Note that the design anJ operational review criterion was changed from the operational limits of 10 CFR Part 20 (NUREG-0578) to the GDC 19 criterion (October 30, 1979 letter from H.
R. Denton to all licensees).
On Hay 26, 1982, the St. Luci e Unit 1 Chemi stry.and Health Physics Departments staged a drill to demonstrate the capability to obtain and analyze reactor coolant liquid and contairment gas samples under post-accident conditions.
This was done in accordance with the St. Lucie Plant Emergency Plan.
The drill.critique was provided to the NRC Resident Inspector and
.i s avail able for revi ew.
Criterion:
(7)
The analysi s of primary coolant sampl es for boron i s required for PWR.
(Note that Rev.
2 of Regulatory Guide 1.97 specifies the need for primary coolant boron analysis capability at BWR plants).
RESPONSE
St. Lucie Unit 1 has the ability to sample and analyze the Reactor Coolant System for boron in a post-accident situation.
St. Lucie
Criterion:
RESPONSE
Unit 1 Chemistry Procedure Ho. C-ill "Establishing Remote Analysis Laboratory, Counting Laboratory, and Counting Procedures for Accident Samples" addresses the boron analysis.
(8) If in-line monitoring is used for any sampling and analytical capability specified herein, the licensee shall provide backup sampling through grab
- samples, and shall demonstrate the capability of analyzing the samples.
Established planning for analysis at offsite facilities is acceptable.
Equipment provided for backup sampling shall be capable of providing at least one sample per day for 7 days following onset of the accident, and at least one sample per week until the accident condition no longer exi sts.
The PASS System P
5 ID shows the capability to draw diluted and undiluted grab samples.
Also shown i s the capabi 1,i ty to flush the system with demineralized water.
Chemistry Procedures C-110, "Collecting Initial Set of Post Accident Samples and Guidelines for Establishing Post Accident Water and Gas Inventory Control",
C-ill, "Establishing Remote Analysis Laboratory, Counting Laboratory, and Counting Procedures for Accident Samples",
and
.C 112, "Operation and Calibration of the Hilton Roy, Post Accident Sampling System" discuss the St. Lucie Unit 1 sampling and analytical capabilities.
In addition, the St. Lucie Unit 2 lao can be used as a remote lab.
Criterion:
(9)
The licensee's radiological ana chenical sample analysis capabiity shall include provisions:
(a)
Identify and quantify the isotopes of the nuclide categories discussed above to levels'corresponding to the source terms given in Regulatory Guide 1.3 or 1.4 and 1.7.
Where necessary and practicable, the ability to dilute samples to provide capability for measurement and reduction of personnel exposure should be provided.
Sensitivity of onsite liquid sample analysis capability should be such as to permit measurement of nuclide concentration in the range frcm approximately luCi/g to 10 Ci/g.
(b)
Restrict background levels of radiation in the radiological and chemical analysis facility from sources such that the sample analysis will provide results with an acceptably small error (approximately a factor of 2).
This can be acccmpli shed through the use of sufficient shielding around samples and outside
- sources, and by the use of a ventilation. system design which will
RESPONSE
Identification and quantification of radionuclides in samples of reactor coolant and the contairrnent atmosphere that may be indicators of the degrees of core damage (e.g., noble
- gases, iodines, and cesiums, and non-volatile isotopes) is provided by grab sampling and transport for remote counting.
The PASS System provides the capability to dilute these samples based upon considerations contained in Regulatory Guides 1.4 and 1.7.
Guidance for counting of those
- samples, including considerations for background error, is provided in St. Lucie Unit No.
1 Procedures C-ill, "Establi shing Remote Analysis Laboratory, Counting Laboratory, and Counting Procedure for Accident Analysis and C-48A, "Operation of ND 6685 Computer Based Counting System".
Criterion:
10 Accuracy, range, and sensitivity shall be adequate to provide pertinent data to the operator in order to describe radiological and chemical status of the reactor coolant systems.
RESPONSE
The PASS instrumentation meets the reccmmended ranges pr ovided in Regulatory Guide 1.97 Revision 2.
A quality control program exists that assures that accuracy, range and sensitivity of the PASS Instrument are adequate to provide pertinent data to the operator in order to describe radiological and chemical status of the reactor coolant system.
As an added
The boron analysis was found to be satisfactory.
However, it was determined that the chloride results were not satisfactory using the four ASTtl methods.
namely:
~ mercuric nitrate titration, silver nitrate
- analysis, thiocyanate analysis and specific ion probe analyses.
In addition, because of the way samples will be drawn and analyzed at St.
Luci e Unit 1, there i s no need to i ncl ude gross act ivity and hydrogen in the test matrix.
Criterion:
(11)
In the design of the post accident sampling and analysis capabiity, consideration should be given to the following
~
items:
(a)
Provisions for purging sample lines, for reducing plateout in sample lines, for minimizing sample loss or distortion, for preventing blockage-of sample lines Dy loose material in the RCS or containment, for appropriate disposal of the samples, and for flow
,restrictions to limit reactor coolant loss from a
rupture of the sample line.
The post accident reactor
coolant and containment atmosphere samples should be representative of the reactor coolant in the core area and the containment atmosphere following a transi ent or accident.
The sample lines should be as short as possible to mi nimi ze the volume of fluid to be taken frcm contaireent.
The residues of sample collection should be returned to containment or to a closed system.
(b)
The ventilation exhaust frao the sampling station should be filtered with charcoal absorbers and high-efficiency particulate air (HEPA) filters.
RESPONSE
Sample line purging is accomplished by demineralized water flushing.
All lines in skid 2 are flushed with 80 psig water press ure.
Sample line blockage is prevented by a strainer in skid 1 which also has backwash provisions.
All samples flowing through the skid 2 sample assembly are routed to the reactor drain tank, thus returning all contaminated water
,back to the conta i ree nt bui 1 di ng.
The reactor coolant sample is drawn from the 1A1 Hot Leg.
If for
. some reason this sample becomes unrepresentative, we have the capability to sample from the shutdown cooling pump discharge line,'which will be a representative core area sample.
The ventilation system for the sampling area is routed to the emergency core cooling system ventilation system which has installed HEPA and charcoal filters.
ATTACHMENT 2 FSAR SECTION 9.3.7 POST ACCIDENT SAMPLING SYSTEM
'Ihe Post Accident Sampling System (PASS) consists of shielded skid~ounted sample stations and local control panel.
The PASS provides a means to obtain and analyze pressurized and unpressurized, diluted and undiluted reactor coolant samples and containment building samples.
Tne Post Accident Sampling System (PASS) is designed based upon the criteria set forth in N~JREG&660 as modified by Section II.B.3 of NUREG&737 which deals with implementation of capabilities for sa=pling reactor'oolant during postwccident condition.
As such, the system is designed with the following design bas~~:
."minimize personnel radiological expos res.
b)
."'mplify sample system operational requirements for collecting post-accident reactor coolant chemist=y and radiochemistry information.
9.3-49
c)
. e) p
)
The capability to cool and depressurize samples from lines with high temperatures and pressures to allow for safe handling
~
"Continuously accept reactor coolant samples and separate the dissolved gases from the liquid.
U Provisions for obtaining representative reactor coolant samples from hot leg (high pressure) and containment sump (recirculation) samples from the low pressure safety injection pump discharge (low ressure Indicate and record the dissolved oxygen concentration and pH of the liquid phase.
Provision for taking diluted liquid grab samples (up to 1:1000 dilution) for chloride, boron and radioisotopic analysis.
h)
Provision to measure and record continuously degased liquid flow.
Pruvision to measure and record continuously the flow of gas separated from the liquid.
Indi cate and record continuously hydrogen content in the gas phase.
Prov i.sion for taking variable dilution of gas grab samples having di inc'ion range up'to 1:1000.
Sample flow is returned to the containment to preclude unnecessary co>>tamin tion of other auxiliary systems and to ensure that radioactive waste remains isolated within the containment.
- 9. 3-7 ~ 2 System Descri tion The Piping and Instrumentation diagrams for the PASS are shown on Figures
- 9. 3-8:
The post-accident sampling system samples are taken from the hot leg piping of the reactor coolant loop or from the LPSI discharge.
Ei ther a reactor coolant (main loop) sample or a containment sump sample may be taken by opening the associated solenoid valve at the sample collection station.
The sample is then passed through an existing sample cooler where it is cooled to about 90 F.
b)
The sample is then depressurized to 70 psig by passing through a
pressure reducing valve station.
Due to the high amounts of dissolved gases in the sample there is two-phase flop upon sample de pressurization.
For this reason the gases mus t be separated from the liquid, analyzed and then correlated to quantify the desired pa c a~e ter s in the original sample.
c)
The cooled and depressurized sample passes through a gas-liquid separation system consisting of a line separator, a gas separator a<<d a gas release valve.
9.3-50
d)
The line separator is the first stage in the separation system.
Liquid enters the top and is spinned, causing the liquid to be forced to the side and the gas to the center of the line separator.
'Ihe resulting streams pass to the gas separator.
'Ihe gas separator is a packed column with a mist el'iminator to ensure complete gas-liquid separation and avoid liquid carryover.
An external gas release valve controls the release of the gas and also maintains the desired liquid level in the separator.
'Ihe liquid is continuously withdrawn at the bottom of the gas separator, while the gas exits the top of the separator through the gas release valve.
e)
Iiquid passes through a magnetic flow meter where the flow'rate 'is measured and recorded, a 5may valve, dissolved oxygen and pH
- probes, and finally to the reactor coolant drain tank.
To obtain a
di.luted grab sample the liquid is passed through a 4~ay valve ~
By changing the valve position an exact amount of liquid is captured in the straight bore.
Ih'e captured sample is, flushed out with a v =quired amount of demineralized water, depending on the dilution desired (i.e.,
1:250, 1:500, 1:1000, etc.),
to a shielded diluted gr'ib sample container.. The diluted grab sample is then transported to the onsite laboratory.
The diluted grab sample is analyzed for boron, chlorides and radioisotopes.
Provisions for flushing all I ines and for rem'ote pH and 02 calibration have been made.
9.3.i.3
'Ih>> gas passes through a pulsation dampener to smooth out fl>>ctuations in flow.
Ihe gas flow rate is measured and recorded l>y a linear mass flow meter.
'Ihe gas is diluted with nitrogen in a gas blKnder and passes through an in-line hydrogen analyze".
~
A diluted grab sample is collected in container and transported to.
t.'he laboratory for noble gases analysis.
All excess gases are vented (or blown) to the containment.
Provisions have been mde for the complete purging of the system.
Coin onent Description The major PASS components and data sugary are given in Table 9.3-30.
9.3-51
TADl.E 9.3-30 IOST ACC IDFHT SAHI'I,IHC SYSTEM G)HNtlEHT DATA
SUMMARY
HAJOR (OMlQllENTS All the following components, are supplied in four (4) nsjor prefabricated skids:
l.
Sample Selection and Strainer Station 2.
Prcssure Reduction and Sampling Station 3.
Ihasc Sepnrntor 4.
Control Console COMPOHENS Magnetic Flow Heter (Liquid)
Linear Mass Flow Meter (CAS)
DFSCRI PT IOH Flow Rate:
Up to 2000 cc man Instrument with signal converter and recorder Flow Rate:
Up to 5000 cc(STP)/min Instrument with digital readout box.
S KID/LOC 2/4 Cas Blender pll Meter Hydrogen Analyzer Dissolved Oxygen Anal yser Cas Crab Sample Cylinder Cas Separator with Gas Release Valve Prcssure Indicator Up to 1:1000 dilution.
Thc probe holder has been designed to minimire fluid volume.
1he pH probe will bc calibrated remotely.
Range 1-13; expanded range 0-14 ~
Sensitivity 0.5X full scale (O.OG pll units)
~
Indicate 6 record Mz concentration continu-ously with provisions for minor calibration.
Instrument in explosion proof.
Range 0-100X Volume.
Scns it ivi ty:
2X of full scale.
Indicate 6 record 02 concentration continu-ously with provisions for remote calibration.
Range'.
0-5, 0-10, 0-20 ppm',
0-100X air satu-rntion.
Sensitivity:
+3X at 0"45 C
+1X within +5 C of calibration temp
~
45cc stainless steel, double cndcd, sampling cylinder with isolating nccdlc valves, lcak-tight quick-connects with double ended shutoff fittings on both sides.
Stainless stccl construction, dcsigncd for total gas separation at design conditions.
At steady state operation, thc gas rclcasc valve will maintain normal liquid level.
Range.'.
0-2500 ps ig 2/4 2/4 2/4 2/4 1/4
P I'I
TADLE 9. 3"30 (Cont')
CO HIQNENTS DFSCR(PT ION SKID/LOG Pressure Indicator
'VFu t fad'aeter Temperature indicator Cas Sample Eecirc Pump
- Strainer
- Pulsation Ibmpencr 1-150 ps ig 50-600 50-150 P
Provided to return paste Sas to containment Stainless Steel Stainless Steel approx 1000cc 1/4 I/4 1/4 Dilution DI Mater Cy 1 ind er Graduated or calibrated to accurately deliver the desired dilution volume.
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