ML17334A974
| ML17334A974 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/23/1986 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM AEP:NRC:0678W, AEP:NRC:678W, NUDOCS 8606300301 | |
| Download: ML17334A974 (10) | |
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ACCESSION NBR: 860630030i DOC. DATE: 86/06/23 NOTARIZED:
NO DOC)(ET FACIL:50-3i 5 Donald C.
Cook Nuclear Poeer Plant'nit ii Ind iana Kc 050003i 5 50-3i6 Donald C.
Cook Nuclear Power Planti Unit 2>
Indiana i~c 050003ih AUTH. NAl'tE AUTHOR AFFILIATION ALEXICH, a>. P.
Indiana 8c Michigan Electric Co.
REC IP. NANE RECIPIENT AFFILIATION DENTONp H. R OPfice oF Nuclear Reactor Regulationi Director (post 85ii25
SUBJECT:
Forwards evaluation Rc discussion oF alternative methods for noble gas monitoring 8c i odine/particulate sampling sos> per util 860219 itr re NUREQ-0737> Sections II. B. 3 8c II. F. i.
Exemption requests listed.
DISTRIBUTION CODE:
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INDIANA8 MICHIGAN ELECTRIC COINPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 June 23, 1986 AEP:NRC:0678W Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 MONITORING AND SAMPLING RADIOACTIVE EFFLUENTS NUREG-0737, SECTIONS II.F.1-1 AND.II.F.1-2 Mr. Harold R. Denton, Director Office of Nuclear Regulatory Regulation
'.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
In our letter AEP:NRC:0678S, dated February 19,
- 1986, we provided a summary of the actions we planned to take with regard to Section II.B.3 and II.F.1 of NUREG-0737.
As a follow-up to Items IV and V of that letter, we are now transmitting our evaluation of the radioactive source terms for the steam jet air ejector (SJAE) and gland seal condenser (GSC) exhaust.
The attachment to this letter contains this evaluation and also discusses an alternative method for sampling iodine from these two exhaust pathways.
As a result of this evaluation, we are requesting exemptions from NUREG-0737 for the following items:
- l. Iodine/particulate source term requirement in Section II.F.1-2 for the SJAE and GSC exhaust systems.
2.
The design range requirement of 10 uCi/cc for noble gas monitoring 5
of the GSC exhaust as required in Section II.F.1-1.
The low-range noble gas detector will be the only one used on this release pathway.
- 3. Iodine grab and continuous sampling capability for the SJAE and GSC exhaust pathways as required in Section II.F.1-2.
We have an alternative method for estimating iodine releases.
- 4. Particulate sampling capability for the SJAE and GSC.
- These, exhausts are not potential release pathways for particulates.
Our schedule for closing out NUREG-0737 Sections II.F.l-l and II.F.1-2 is dependent on the NRC's response to the above requests for exemption.
8bOb300301 8bOb23 PDR ADOCK 05000315 P
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~ g Mr. Harold R. Denton AEP:NRC:0678W Pursuant to the requirements of 10 CFR 170.12(c),
we have enclosed an application fee of $150.00 for review of this exemption request.
This document has'been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, I
M.
. Ale ich Pl Vice President gf'P~
cm Attachments cc:
John E. Dolan W.
G. Smith, Jr.
- Bridgman R.
C. Callen G.
Bruchmann G. Charnoff NRC Resident Inspector
- Bridgman
Attachment to AEP: NRC: 06789 Evaluation of the D.
C.
Cook Nuclear Plant, Noble Gas Monitoring and Iodine/Particulate Sampling Systems PURPOSE The purpose of this analysis was to evaluate our present post-accident noble gas monitoring and iodine/particulate sampling systems for the steam jet air ejector (SJAE) and gland seal condenser (GSC) exhaust pathways in the context of NUREG-0737 Sections II.F.1-1 and II.F.1-2.
The analysis encompassed the types and amounts of radioactivity that would be expected to be released to the atmosphere through the SJAE and GSC exhaust pathways from the main steam
- system, as a result of a postulated accident.
ACCIDENT SCENARIO The following two worst-case accident scenarios were considered in this analysis:
(1) the steam generator tube rupture with 1% of failed fuel, and (2) a LOCA resulting in cladding and fuel damage, with a 1-gpm leak rate from the primary to the secondary side.
To use the LOCA scenario, there must be a greater pressure in the primary side than in the secondary side after fission products are released into the reactor coolant as the result of fuel damage.
After an investigation of this criterion and a review of Appendix 14.F of the FSAR, Major LOCA Analysis, it was concluded that in all cases, the blowdown phase of the transient ends before hot rod burst time, alleviating the driving force from the primary to secondary side after fission products appear in the reactor coolant system.
Therefore, the LOCA with fuel damage scenario would be an inappropriate scenario to be used for the determination of an accident source term for the main steam system.
The accident scenario used for determining the main steam radionuclide concentration
- was, then, a steam generator tube rupture.
ASSUMPTIONS For the analysis of the steam generator tube rupture accident scenario, the following assumptions were determined to be the most conservative:
1.
The break occurred high up on the steam generator tube bundles.
2.
No credit was taken for the transfer of radiation to the steam generator water.
3.
All noble gas particulates and iodines entered the main steam system (upper bound model of Reference 1).
0 Attachment to AEP:NRC:0678W 4.
1% of the reactor's fuel contained clad defects.
5.
Iodine spiking resulted from a series of reactor transients.
As the result of the iodine spiking assumption, a multiplier of 500 was applied.
This multiplier was the highest found'n the reference material reviewed.
6.
The primary-to-secondary leak rate remained constant.
7.
The steam generator blowdown was isolated and remained isolated during the duration of the accident.
8.
There was no deposition of iodine on any surface.
RESULTS CONCLUSIONS The results of our analysis are as follows:
Concentrations Radionuclide Main Steam System
~uCi cc SJAE Exhaus t
~uCi cc GSC Exhaust
~uCi cc Iodine 2.07 1.54 x 10 1.03 x 10 Particulate Noble Gas 4.06 x 10 1.87 x 10 1.97 x 10 5.48 x 10 In conclusion, as shown above, the 100 uCi/cc of iodine and 100 uCi/cc of particulates that are a required source term in NUREG-0737,Section II.F.1-2 are unreasonably conservative for the SJAE and GSC exhaust systems.
We therefore request exemption from using these source terms for these two pathways.
The noble gas design range requirement of 10 uCi/cc for the GSC exhaust 5
pathway is also unreasona)ly conserva)ive.
The present low-range noble gas detector (range - 1 x 10 to 1 x 10 uCi/cc) is adequate for measuring:
releases of5noble gases from this pathway.
We therefore request exemption from the 10 uCi/cc range requirement of NUREG-0737,Section II.F.1-1 for the GSC exhaust.
In our analysis low concentrations of iodine would be released from the SJAE and GSC pathways.
The analysis did not include iodine line-loss in the main steam system and sample lines, which would also lower these values significantly, in accordance with Refer'ence 2.
Dealing with such unknown losses and low concentrations, taking iodine grab samples and/or having a continuous sampling system would not provide a reasonable source of information for quantitative analysis and/or off-site dose assessment.
Since our prime objective is to protect the health and safety of the public, we propose the following alternative method for an iodine release from the SJAE and GSC exhaust systems.
Attachment to AEP:NRC:0678W Since noble gas is constantly'monitored for these release
- pathways, and since there will be field teams available for sampling the surrounding environment, we propose to develop a ratio between the calculated secondary coolant noble gas and iodine.
We will then apply this noble gas/iodine ratio correction to the noble gas monitor reading to predict the expected iodine reading.
We will also compare the expected iodine with field data on iodine and adjust the correction factor if necessary.
We believe this proposed method will more realistically protect the health and safety of the public.
We therefore request exemption from NUREG-0737 Section II.F.1-2 for sampling iodine released from the SJAE and GSC exhaust pathways.
In addition, iodine particulates were considered in this analysis as an iodine release and were assumed to be adsorbed on the iodine filters.
Other particulates would remain in the main steam/feedwater systems and would not be released to the atmosphere.
We therefore request exemption from sampling of particulates from the SJAE and GSC exhaust pathways.
REFERENCES (1)
BNL-NUREG-24994 "Radioactivity Release vs. Probability for a Steam Generator Tube Rupture Accident" (1978)
(2)
"Deposition of Airborne Radioiodine Species of Surfaces of Metals and Plastics."
M. J. Kabat; Ontario Hydro, Health and Safety Division ADDITIONAL SOURCES OF INFORMATION NUREG-0017, Rev.
1 "Calculation of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Water Reactors" (1985)
- "Iodine Behavior in a PWR Cooling System Following a Postulated Steam Generator Tube Rupture Accident" (1978)
NUREG/CR-2683//BMI-2094 "Iodine Behavior in Steam Generator Tube Rupture Accidents" (1982)
June:20,-I986.
DOCKET NO(S).:
50-315/316 ter. John Dolan, Vice President Indiana and flichigan Electric Company c/o American Electric Power Service Corp.
1 Riverside Plaza
- Columbus, Ohio 43216 D. C.
Cook Nuclear Plant, Units 1 and 2
, DI
-IBUT;ION: wj'o enc'1'osure i-- Docket File NRC PDR Local PDR PRC System NSIC PWR¹4 Rdg HDuncan DWigginton BJYoungblood OELD ACRS (10)
JPartlow BGrimes EJordan NThompson The following documents concerning our review of the subject facility are transmitted for your information.
D Notice of Receipt of Application, dated D Draft/Final Environmental Statment, dated D Notice of Availabilityof Draft/Final Environmental Statement, dated D Safety Evaluation Report, or Supplement No.
, dated D Notice of Hearing on Application for Construction Permit, dated D Notice of Consideration of Issuance of Facility Operating License, dated I'
Q Monthly Notice; Applications and Amendments to Operating Licenses Involving no Significant Hazards Considerations, dated (See page 22238)
D Application and Safety Analysi's Report, Volume D Amendment No.
to Application/SAR dated D Construction Permit No. CPPR-D Facility Operating License No.
, Amendment No.
, Amendment No.
dated
, dated D Order Extending Construction Completion Date, dated D Other (Specify/
Enclosures:
As stated Office of Nuclear Reactor Regulation cc:
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