ML18046A844
| ML18046A844 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/03/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-06-01, TASK-6-1, TASK-RR LSO5-81-08-006, LSO5-81-8-6, NUDOCS 8108050271 | |
| Download: ML18046A844 (9) | |
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August 3, 1981 DOc ket No. '50-255 LS05~a1-oa-006
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Mr. David. Pl Hoffman Nuclear Licensing Administrator Consumers Poi~r Company 194.5 w~,,Parnall Road Jac~sc;>n.~:--Michigan 49201
Dear Mr. Hoffman:
SuPJECT:
SEP TOPIC v1-1, ORGANIC MATE~IALS AND Pos'r ACCIDENT c~_ltnSTRY
( PALISADE_S PLANT)
By letter dated*March.12, 1981 we forwarded* to you*~~
1ur <t~,aftevaluat1on of SE~ Topic VJ'!"l, "Organic Materials and Post Accident -Chemistry" for the Palhades_plant. Yobr response ~ated July 17, 1981 indicated that the ev~l uat1on was correct except* for our statern.ent that no surve11 lance requirements existed for sampling the hydro~1.r1e and sodium hydroxide tanks.
We have re-v1 ewed the pl ant technical spedfica,t1ons and. found that. the. necessary. sur*
v~lance r~quirements do exist. Th-erefore we have revised our evaluation* to remove the recommendation regarding adding surveillance requirements. Our final evalu~tion on Topic Vl-1 is enclosed-*
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This evaluet,t1on w111 beia basic input' to the integrated safety assessment :for"*
your facility... This assessment may be revised in the future if your fCt.C'11 ity design is changed or if the NRC criteria relating to this subject is modified befof,~ the 1ntegrated assessment is complete..
Sincerely, r* *-
/;a~-50271 81080~ "1 ~
1j P.DR APOCK -05000255.
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Dennis M. Crutchfield, Chief Opera t1 ng Reactors Branch No*. 5 Division of Licensing s'fP'f
Enclosure:
As stated
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- *uSGPO: 1980-329*824
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Mr. David P. Hoffman cc
. M. I. Miller, Esquire Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60670 Mr. Paul A. Perry, Secretary Consumers Power Corrµany 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Co!ll)any.
212 West Michigan Avenue Jackson, Michigan 49201 Myron M.
Cherry~ Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 Ms. Mary P. Sinclair Great Lakes E.nergy Alliance 5711 Summerset Ori ve Midland, Michigan 48640
. Ka 1 amazoo Public Library 315 South Rose Street Kalamazoo, Michigan 49006 Township Supervisor Covert Township Route 1, Box 10 Van Buren County; Mi ch'i gan Office of the Governor (2)
Room 1 - Capitol Building Lansing, Michigan 48913 William J. Scanlon, Esquire*
2034 Pauline Boulevard Ann.Arbor, Michigan* 48103 Palisades Plant ATTN:
Mr. Robert Montross Plant Manager Covert, Michigan 49043 49043 PALISADES Docket No. 50-255 U. s. Environmental Protection Agency Federal Activities Branch Region V Office ATTN:
EIS COORDINATOR 230 South Dearborn Street Chicago, Illinois 60604 Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board Panel U. s.* Nuclear Regulatory Corrmission Washington, D. C.
20555 Dr. George c. Anderson Department of Oceanography University of Washington Seattle, Washington 98195 Dr. M. Stanley Livingston
. 1005 Calle Largo Santa Fe, New Mexico 87501 Resident Inspector c/o U. S. NRC P. o. Box 87 South Haven, Michigan 49090
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I NTROOUCT ION y
PALISADES
'1 TOPIC VI-1, ORGANIC MATERI~LS AND POST ACCIDENT CHEMISTRY ENCLOSlJRE The design basis for se.lection of paints and other organic materials is not documented for most operating reactors. Topic VI-1 is intended to review the plant design to assure that *organic materials, such as organic paints and coatings, used inside containment do not behave adversely during accidents when they may be exposed to high radiation fields.
In particular the possi-bility of coatings clogging sump screens should be minimized.
Low pH solutions that may be recirculated within the containment after a Design Basis Accident (OBA) may accelerate chloride stress corrosion cracking and increase the volatility of dissolved iodines.
The objective of Topic VI-1 is to assure that appropriate methods are available to raise or maintain the pH of solutions expected to be recireulated within containment after a OBA.
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Organic Materials:
~n a~sessment of the suitability of organic materials in the conta.inment includes the review of paints and other organic materials used inside the containment including the possible interactions of the de-composition products of organic materials with Engineered Safety Features (ESF), such as filters.
I Post Accident Chemistry:
An assessment of post accident chemistry includes a determination of proper water c~emistry in the containment spray during the injection phase following a OBA and that appropriate methods are available to raise or maintain the pH of mixed solution in the containment sump.
II.
REVIEW CRITERIA Organic Materials:
The plant design was reviewed with regard to GenP.ral Design Criterion l, "Quality Standards and Records" of Appendix A to 10 CFR Part 50, -"General Design Criteria for Nuclear Power Plants" which requires that structures and systems important to safety be d*esigned and tested to quality standards commensurate with the importance of the safety function to be performed.
Als~ contained in the review was Appendix B to_ 10 CFR 50, "Quality Assurance Criteria for Nuclear Power Plant~ and Fuel Reprocessing Plants." This guide describes an acceptable method of complying with the Conmissions quality assurance requirements with reg~rd to protective coatings.
Post Accident Chemistry:
The design was reviewed with regard to General:.*Design Criterion 14, "Reactor Coolant Pressure Boundary" of Appendix A to 10 CFR Part
- 50. - This requires that the reactor coolant pressure boundary be designed and erected so as to have an extremely lOw probability of abnormal leakage and gross rupture. Also, regarded in the review was General Oesign Criterion 41, 11Containment Atri'iosphere Cleanup," of Appendix A to 10 CFR Part 50.
This requires* that systems to ccntrol substances released in reactor containment
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be provided to reduce the concentration and quality of fission products releas*ed to the environment following a po~tulated accident.
III.
RELATED SAFETY TOPICS The effectiveness of the iodine removal system is evaluated as part of Topic XV-19, for a spectrum of loss~of-coolant accidents.
Topic VI-7.E reviews the ECCS in the recirculation mode to confirm the effectiveness of the ECCS.
IV.
REVIEW GUIDELINES Organic Materials:
Current guidance for the review of organic materials in containment is provided in Sections 6.1.1 "Engineered Safety Features Materials" and 6.1.2 "Organic ~1aterials" of the Standard Review Plan and in Regulatory Guide 1. 54 "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants." Regulatory Guide 1.54 endorses the requirements and guidelines described in detail in ANSI NlOl.4-1972 "Quality Assurance for Protective Coatings (Paints) for the Nuclear Industry.*"
Post Accident Chemistrv:
Guiaance for the review of post accident chemistry is provided in Sections 6.1.l, 6.1.2. and 6.5.2 of the Standard Review Plan.
Sections 6.1.1 and 6.1.2 are related to assuring that appropriate methods are available to raise or maintain the pH of the ~ixture of the containment spray, ECCS water, and chemical additives for reactivity control and iodine fission product removal in the cuntainment sump during the recirculation phase and to preclude 1ona term corrosion ;:iroblems after the accident.
Section 6.5.2 is related to providing proper wate~ chemistry in the contain-ment spray during the injection phase following a Design Casis Accident.
V.
EVALUATION Organic Materials:
By letter dated July 30, 1979, the licensee provided references to the types, amounts and the environmental testing of organic coating materials used in the Palisades Plant.
The electrical cable insulation referred to in this letter is reviewed in N~REG-0458 (Reference 1).
Protective coating systems compris~ the: bulk of the **organic materials (outside of electrical cable insulation) in the containment. **Mos-t of the plant surfaces were coated with an inorganic zinc primer and an inorganic zinc top coat containing a lesser proportion of zinc.
Bo.. th coats were of the modified phenolic resin type.
Some plant surfaces were protected by coatings of the generic epoxy anc ph~no1ic types.
- we have reviewed the use of organic materials in contafnment agains~ ~urrent criteria.to assure that any degradation of organic materials under accident conditions will not interfere with the operation of engineered safety features.
Excessive flaking and peeling of paint from containment surfaces following a Design Basis Accident (OBA) might plug safety-related screens, filters, pumps and valves.
Excessive generation of volatile org~nic compounds might saturate the charcoal filters in the containment purge system and interfere with the trapping of radioactive organic iodin~s.
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.. Coatings of the inorganic zinc, phenolic and epoxy types have been subjected to environmental testing involving exposures to the intense radiation, temperature, and chemical conditions during and following a OBA.
In evaluating the radiatior. resistance of the coatings, we used the results in ORNL-3589 (Reference 2) and ORNL-3916 (Reference 3), which describe radiation tests on about 60 coating systems exposed to intense ganuna radiation.
The test results show that the principal types of coatings used in the containment remained serviceable after larger radiation doses than expected during a OBA.
On this basis, we conclude that radiation damage to the organic coatings does not pose a significant hazard to the operation of engineered safety features during a OBA.
- Certain small surface areas in plant equipment were coated with red lead primer and other standard industrial coatings where radiation resistance has not been tested.
However, because only small areas of these coatings are exposed in the Palisades containment, we conclude that their failure under accident conditions *~ould not present a significant safety hazards.
Very small amounts of gas evolved when aromatic organic compounds of the types found in radiation-resistant plastics age irradiated.
For example, a phenolic plastic irradiated to a dose of 10 rads produced 3 ml (STP) of gas per gram of plastic (Reference 4).
For the approximately 100 cubic feet of organic coating existing in the containment, approximately 35 cubic fe§t of gas would be generated for the tonservatively estimated OBA dose of 10 rads.
The gas is mostly hydrogen and l~ss than a tenth of it is volatile organic compounds.
The presence of this small amount of organic gases in containment after a OBA would not interfere with the absorption of organic iodines by the purge charcoal filter..
The amount of hydrogen from this source is small compared to that which
- could be produced iri a OBA from the zirconium-water reaction, from the radiolysis of water, or from the reaction of the zinc or inorganic zinc coatings with high temperature.borate solutions (Reference 5). Hydrogen generation from the latter sources will be revie\\'fed under SEPTopic Vl-5, "Combustible Gas Control."
The inorganic zinc coating was subjected to ther~al and chemical testing by the manufacturer.
Samples were submerged in boron solutions at a pH of 9.5 for several hours at temperatures up to 2851iF.
ORNL tests (
Reference:
'5) on hydrogen generation from inorganic zinc coatings ~mmersed in boiling boron solutions showed considerable hydrogen generation but negligible paint deteriora-tion.
- '1 These res 1Jlts are consistent with literature infonnation (Reference 6) that many organic polymers, in particular phenolic and epoxy resins, are stable to temperatures of the order of 3QQOF and to mildly acidic or basic dilute aqueous solutions.
On the basis of the above information, we find that there is reasonable assurance that the thermal and*themical resistance of the organic coatings used in the plant is sufficiently high that deterioration under DBA condi-tions would not interfere with the operation of engineered safety features.
Exact information is not avai1ab1e or. the present condition of the coatings used in the plant. Therefore, we will request that the licensee make a visual inspection of the coatings inside containment during a future power outage.
The amounts of flaking, peeling, rusting, cracking, blistering and delamination should be recorded.
The inspection and documentation procedures should follow the guidelines for the e~amination of test specimens from weathering and chemical exposure tests?given in ANSI NlOl.2 - 1972, ANSI NlOl.4 -
1972 and ANSI NS.12-1974.
Post Accident Chemistry:
The licensee, by letters dated March 9 and March 30, 1978, proposed a reevaluation of the P~lis~rlPs Pl~nt iodine remova*1 system.
NRC authorized the proposed changes to enhance the performance and control of the Palisades iodine Removal System by issuing Amendment No. 40 to Provisional Operating License No.
DPR~2o. According to this Amendment, the licensee provided an iodine Removal Hydrazine Tank con-taining 270+ 17 gallons of 15.5 + 0.5 percent by weight of hydrazine solution with a nitrogen cover gas pre~sure of 11.2 + 2 psig, and an Iodine Removal Makeup Sodium Hydroxide Tank containing a m'inimum 4200 + 300 gallons of 30
.:!:. 0.5 percent by weight sodium hydroxide with a nitrogen gas cover.
The minute after a containment high pressure signal the Iodine Removal System automatically inj~cts hydrazine solution into the containment.spray water to provide a minimum 50 ppm hydrazine to reduce the post-accident level of iodine fission products in the containment atmosphere.
The sodium hydroxide is manually injected shortly following the start of recirculation spray flow (within one hour post-LOCA) to raise the pH of the boric acid solution to preclude chloride stress corrosion cracking and long term corrosion of safety related structures.
It also increases the cor.tainment spr~y/sump solution* iodine partition factor to enhance the affinity for iodine removal within containment and prevent the reevolution of iodine from the recirculation water.
We evaluated the hydrazine concentration in the containment $pruy during the *
. __ spray_injection phase_and the pH of the sodium hydroxide added to the borfc acid ECCS water ~uring the recirc~latioip~a~e. We alsti~valuated th~ ~torag~
of chemical additive solutions and the containment sump design to promote mixing of the ECCS and spray solutions. Finally, we reviewed the ECCS Safety Injection Tanks Technical Specifications.
We evaluated the post-accident chemical concentration and pH of the contain-ment spray and sump water and have determined that the Palisades Plant meets SRP 6.5.2 and GDC 41 in the following areas:
- 1. During the injection phase, the Iodine Removal System contains adequate quantity and concentration of hydrazine to assure that the containment spray hydrazine ~oncentration will exceed 50 ppm.
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We verified by independent calculation that during the recirculation phase, the minimum pH of 8.5 can be assured for all modes for Iodine Removal Makeup Sodium Hydroxide Tank system operation.
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The design of the containment sump assures that the mixing of ECCS and spray solutions prevents high or low pH values from system "dead" volumes.
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The design objectives of the system for storage of chemical additives in a state of readiness whenever the reactor is critical during the design life of the plant are met.
The chemical addition tanks have a nitrogen cover gas to preclude chemical reaction and decomposition of the chemicals.
The tanks and associated piping are heat traced to prevent precipitation of chemicals or freezing.
Also, during the recirculation phase, the Iodine Removal Makeup Sodium Hydroxide Tank provides an adequat: volume and concentration of sodium hydroxide for addition to the ECCS and spray solutions to meet the minimum 7.0 pH requirement of SRP 6.1.1, BTP MTEB 6-1 and GDC 14 for inhibition of stress corrosion cracking for the prevention of abnormal leakage or failure of the reactor coolant pressure boundary.
We have evaluated the present lechnical Specifications and find that limiting cond 1t1on-s 'of operatio-r't **and the'"peribdie surveillance. requfr'em-erits of 'the***-..
_)~_~Jn~_~_e)!l()yal_ Sy~t~f11 __ a.~c __ ep~a~l_e_ *. _.. --* ____________________________
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VI.
CONCLUSIONS Organic Materials: Tests have demonstrated that the types of organic coating materials used in the containment remained in serviceable conditioo after exposure.to the severe environmental conditions of a*osA.
These test results,.*
.and the fact that the coatings were applied using methods consistent with
- good industrial practice, indicate that the coatings will maintain their integrity under accident conditions.
Neverthel es-s, because t'he present-condition of the coatings ;s not ~xactly known and since they were applied before the guidance of Regulatory Guide 1.54 was available, we will request that the licensee. make a visual inspection of all exposed coated surfaces in containment according to the ANSI guide-lines. All significantly degraded areas shall be repaired according to the ANSI standards.
The results of the inspection and repair shall be documented by the licen:ee.-ind ~e available for NRC review.
- Based on the above, we conclude that there is reasonable assurance that the integrity of organic coatings within the containment will be maintained under normal operat.ing conditions and those of a OBA. and that there will be no undue hazard to the health and safety of the public.
Post Accident Chemistry:
On the basis of the above evaluation, we conclude that the Palisades Plant Iodine Removal System meets the post accident chemistry requirements of SRP 6.5.2 and GDC 41 and SRP 6.1.1 BTP MTEB 6-1 and GDC 14 and is, therefore, acceptable.
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References
- 1.
NUREG-0458 "Short Term Safety Assessment on the Environmental Qualification of Safety-Related Electrical Equipment of SEP Operating Reactors," May 1978.
- 2.
ORNL-3589, Gamma Radiation Damage and Decontamination Evaluation of Protective Coatings and Other Materials for Hot Laboratory and Fuel Processing Facilities, G.A. West and C.D. Watson, February, 1965.
- 3.
ORNL-3916, Unit Operations Section Quarterly Progress Report, July -
September 1965, M.E. Whatley et al., March 1966, pp 66-75.
- 4.
Radiation Effects on Org~nic Materials, edited by R.O. Bolt and J.G.
Carroll, Academic Press, New York and London, 1963, Chapter 6, p. 239.
S.
H. E. Zittel, "Post-Accident Hydrogen Generation from Protective Coat-ings in Power Reactors," rJuclear Technology.J.Z., 143-6 ( 1973) *
. 6.
Chemical Engineers Handbook, J. H. Perry, Editor, 5th Edition, pp. 23 - 60 to 23 - 62.
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