ML18127A805

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Clinch River ESP - (External_Sender) FW: SER 2.1, 3.5, 15.0 Comments
ML18127A805
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Site: Clinch River
Issue date: 04/24/2018
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Download: ML18127A805 (6)


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ClinchRiverESPHFNPEm Resource From: Schiele, Raymond Joseph <rjschiele@tva.gov>

Sent: Tuesday, April 24, 2018 1:21 PM To: Fetter, Allen Cc: Stout, Daniel Paul

Subject:

[External_Sender] FW: SER 2.1, 3.5, 15.0 Comments Attachments: Comments on Draft SER 2.2, 3.5.1.6, and 15.1.docx Allen, as we discussed, please find attached comments, cataloged in tabular form, on the three draft SER sections. TVA will additionally provide these comments, in both tabular and associated marked up pages, under cover letter within the next week.

Please call me if you have any questions or comments.

Thanks!

Ray Schiele Tennessee Valley Authority Clinch River Nuclear Small Modular Reactor Project Office-423-751-8628 Cell-410-610-2320 rjschiel@tva.gov From: Scott, Roger Dwane Sent: Tuesday, April 24, 2018 12:20 PM To: Schiele, Raymond Joseph

Subject:

SER 2.1, 3.5, 15.0 Comments Comments on SER 2.1-2.2, 3.5 and 15.0 attached.

1

Hearing Identifier: ClinchRiver_ESP_HF_NonPublic Email Number: 513 Mail Envelope Properties (0FA7144D673855418F1030CB8FBF3E612DF70567)

Subject:

[External_Sender] FW: SER 2.1, 3.5, 15.0 Comments Sent Date: 4/24/2018 1:21:27 PM Received Date: 4/24/2018 1:21:52 PM From: Schiele, Raymond Joseph Created By: rjschiele@tva.gov Recipients:

"Stout, Daniel Paul" <dpstout@tva.gov>

Tracking Status: None "Fetter, Allen" <Allen.Fetter@nrc.gov>

Tracking Status: None Post Office: TVACHAXCH8.main.tva.gov Files Size Date & Time MESSAGE 702 4/24/2018 1:21:52 PM Comments on Draft SER 2.2, 3.5.1.6, and 15.1.docx 33509 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

TVA Comments on Draft ACRS Presentations Draft Section Draft Text Comment 2.1 Geography and Demography 2.1.1.4 These two paragraphs refer to the The SSAR does not use the term fourth paragraph CRN Site property in four places CRN Site Property. The SSAR (2 places) and total. defines the CRN Site and the fifth paragraph CRN Property. In the four cases (2 places) described identified, all instances should be CRN Property.

2.1.2.4 This paragraph refers to the CRN The SSAR does not use the term first paragraph Site property in the fifth sentence. CRN Site Property. The SSAR (1 place) defines the CRN Site and the CRN Property. In the case identified, it should be CRN Property.

2.1.3.4 Based on the 2010 U.S. census The 1,090,823 value represents fourth paragraph data, an estimated 1,090,823 2010 residents living between 10 residents are located within 80 km and 50 miles from the CRN Site.

(50 mi) of the CRN Site. The total number of 2010 residents living within 0 to 50 miles of CRN is (1,090,823 +

67,203) or 1,158,026 persons.

Alternatively, the sentence can be rewritten to indicate that the 2010 U. S. census data estimated a population of 1,090,083 residents between 10 and 50 miles from the CRN Site.

2.2 Nearby Industrial, Transportation, and Military Facilities 2.2.1.1 The purpose of the staffs review The list of standard review plans first paragraph of this section is to determine the should include 2.2.1-2.2.2 as the adequacy of information in statement relates to 2.2.1 and meeting regulatory requirements 2.2.2 with regard to the presence concerning the presence and of external hazards.

magnitude of potential external hazards so that the staff can perform its technical review and evaluation consistent with the guidance provided in NUREG-0800, Sections 2.2.3, 3.5.1.5, and 3.5.1.6.

2.2.1.2 There are five industrial facilities, This section of the SER does not first paragraph one major highway, four major mention the Heritage Railroad roads, two natural gas pipelines, Corporation Railway. However, one waterway, five small airports, the rail line is included on page 2-and two airways. 13.

2.2.1.4 Hillsdale Powell Utility District The correct name of the facility is third paragraph Melton Hill WTP Hallsdale Powell Utility District under the Industrial Melton Hill WTP.

facilities heading Page 1 of 4

TVA Comments on Draft ACRS Presentations Draft Section Draft Text Comment 2.2.2.2 The chemicals stored at the The SER appears to be referring first paragraph offsite facilities identified in to the SSAR. Therefore, it should Subsection 2.2.2.1 above are read, SSAR Tables 2.2-2 and provided in detail in Tables 2.2-2 2.2-5.

and 2.2-5.

2.2.2.2 ORNL conducts research and The SSAR states ORNL employs second paragraph development relating to national approximately 4400 employees.

energy and security issues and employs approximately 400 employees.

2.2.2.2 The chemicals stored at ORNL The SER appears to be referring second paragraph identified for possible analysis are to the SSAR. Therefore, it should addressed in Subsection 2.2.3. read, are addressed in SSAR Subsection 2.2.3.

2.2.2.2 TVA Kingston Fossil Plant is The conversion from 7.6 mi third paragraph located in Kingston, TN, should be 12.2 km, not 1.2 km.

approximately 1.2 km (7.6 mi) west of the CRN Site power block area.

2.2.3.4.2 Therefore, the potential chemical The evaluation in the SSAR first paragraph concentration at the center of provided the potential chemical CRN Site (power block boundary) concentration with respect to the is estimated for the purposes of closest point on the power block this evaluation. The chemicals area, not the center of the CRN that lead to concentration above Site (power block boundary).

the respective chemical Immediately Dangerous to Life and Health (IDLH) concentration at the center of CRN site (power block boundary) are further evaluated at the COL stage as part of COLA.

2.2.3.4.2 The chemicals that are The analyzed quantity for third paragraph transported on I-40, which are anhydrous ammonia and butane identified having a toxicity should be 11,500 gal, not lb.

potential include anhydrous ammonia (11,500 lb), butane (11,500 lb), chlorine (22 T or 44,000 lb), gasoline (8,500 gal),

nitric acid (6,000 gal), and sulfur hexafluoride (50,000 lb).

Page 2 of 4

TVA Comments on Draft ACRS Presentations Draft Section Draft Text Comment 2.2.3.4.2 A release of anhydrous ammonia The analysis presented in the third paragraph resulted in a distance of 4,184 m SSAR for nitric acid resulted in a (13,728 ft) to the toxicity limit and distance of 5,280 ft versus the a release of chlorine resulted in a staffs analysis of 8,448 ft.

distance of 7,242 m (23,760 ft). The staffs analysis for a TVA did not receive a request from release of nitric acid resulted in a the staff regarding the difference distance of 2,575 m (8,448 ft). for nitric acid (8,448 ft vs 5,280 ft).

2.2.3.4.6 The permit condition includes the The analysis presented in the Permit Condition evaluation of whether the SSAR for nitric acid determined a 2.2-2 transport of nitric acid on highway distance of 5,280 ft to the toxic I-40 could exceed the IDLH limit at endpoint, which is less than the the CRN Site power block area. distance of 5,800 ft to the CRN Site power block area. Therefore, the evaluation of nitric acid should not be included in the permit condition.

3.5.1.6 Aircraft Hazards 3.5.1.6.2 Airports located beyond 24.1 km The correct table number is SSAR second paragraph (15 miles) are also considered and Table 2.2-7.

are listed in the SSAR Table 2.2.7.

15.1 Accident Analysis 15.1.4.1 In accordance with 10 CFR 10 CFR 52.79(b)(1) indicates that third paragraph 52.79(b)(1), the COLA will verify COLA FSAR may IBR the ESPA that the accident doses provided SSAR and demonstrate that the in the ESPA are bounded or will design of the facility falls within the provide an evaluation of accident site characteristics and design radiological consequences. parameters specified in the early site permit. The SER implies the ESPA falls within COLA; it should say ...doses provided in the ESPA are bounding 15.1.4.1 Although it is recognized that This statement is nearly identical seventh paragraph core power and burnup would to the last sentence of SSAR result in one-to-one ratios to Section 15.2, except that it activity releases, it is anticipated changes the intent of the the larger core power and burnup although clause. The SSAR would result in larger activity says, Although it is recognized releases than those associated that core power and burnup do not with the remaining designs. necessarily result in one-to-one ratios to activity releases Page 3 of 4

TVA Comments on Draft ACRS Presentations Draft Section Draft Text Comment 15.1.4.3 The text following Table 15-1 SER Table 15-1 is missing the last Table 15-1 states, The radiological row of SSAR Table 15-1 that adds consequence results of a LOCA at together the four time ranges for the CRN Site, using the PPE and dose at the LPZ boundary.

site characteristic accident /Q values are 21.6 rem TEDE at the EAB and 2.97 rem TEDE at the LPZ. However, Table 15-1 does not include the total LPZ row indicating 2.97 rem TEDE.

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