ML19211C725

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Responds to Questions in NRC Re Containment Bldg Atmosphere Cleanup.Util Wishes to Meet W/Nrc to Expedite NRC Review & Approval of Request to Purge Reactor Bldg
ML19211C725
Person / Time
Site: Crane 
Issue date: 01/04/1980
From: Wilson R
Metropolitan Edison Co
To: Jay Collins
NRC - TMI-2 Operations/Support Task Force
References
TL002, NUDOCS 8001140297
Download: ML19211C725 (63)
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Text

{{#Wiki_filter:* j 2 gy 74g m py Metrocontan E6 son Cem;:any U l1D ' 52*57 [f"[_*,',3*$3n,, 5,, t 27c57 January 4, 1980 TLOO2 Mr. John T. Collins reputy Dire :or - TMI Support Nuclear Regulatory Cc-nissica 3:ee Mile Island - Trailer #7 M.iddlete n, Pennsylvania 17057

Dear Sir:

Thr ee Mile Island ';uelear Station, Unit 2 (TMI-2) License ?;o. OPR-73 Docke: ?;o. 50-320 Reactor Centain=en: Euilding At=csphere Cleanup Enclosed are the responses to the 33 questiens raised in your letter of Decenber IS, 1979. If you need further explanatien of these respenses to cceplete your Environmental Assessment, please contact Mr. Ed Fuller at (201) 263-6331. We veuld be pleased te meet with you to discuss our re-spenses if that would expedite the ';RC review and approval of our requests to proceed with purging the TMI-2 Reactor 3,uilding. ,_SJncerel, ) .t i u\\ 3....i\\..-- R. F. 'ailsen Director - nfI-2 1741 120 u o.._.,. : g p Enclosures cc: H. Denten R. Vollmer R. Walker D**D_~ D ~3._ 6 J " ',~ =' e tJ'u _ e;9 r a . ell eoa ~t a \\ 0 0, 3\\ \\ 8001140 c,L7 } wc-sa sce:.m,,s e. m eme c-e:-~ S 7 f

ss 4 I g 1. Page 2, Section 1.4 paragraph 1. Justify why solvent extraction process was not considered as one of the feasible methods. The fluorocarbon solven ex:raction syste= was considered as a possible Krypton re= oval =ethod in the early evaluations conducted by Met repolitan Idiscn. Af ter a preli=inary review, the solvent extraction process was deter =ined to be i= practical due :o its develop = ental s: age and due to its unavailabili:y en a ces=ercial basis. Subsequent to this initial conclusion en the solvent extracticn process, Metrepolizan Idisen conducted a further review of the syste= which included a trip to Oak Ridge to discuss pessible use of the sys-te= with its developers at the Oak Ridge National Laboratory. Our dis-cussions with the cogni: ant persennel at Oak Ridge led Metropolitan, Edison to the conclusion that although the fluorocarben solvent extrac-tion process could be used a: TMI, it could not be placed into cperatica at TFH for a significant period of ti=e. The esti= ate of the time period required to place the syste= into operation at TMI, assu=ing co=plete licensing, qualificatien, and NRC interf acing during the design and con-struction process was three to four years. This three to four year period was the time frame esti=a:ed by the personnel at Oak Ridge. Al-though the ti=e period to place a system into operatien that was fully licensed and qualified was esti=ated to be three to four years, Oak Ridge personnel indicated that this syste= could, if all licensing and quali-fication require =ents were eli=inated, be in operation in the neighbo'r-hood of cne to two years. L' sing the info rmation gathered f ro: reports prepared by Oak Ridge perscnnel and fre= our direct discussion with the people at Cak Eldge, Metropolitan Edison has concluded that a two year time period for installation, start-up and test is opti=istic and that the solvent ext raction process, therefore, presents unacceptable delays in trea =ent of the Krypten-35 in the containrent building. These delrys, 1741 1-21

s 3 tt 1. (continued) as discussed in our Nove=ber 13 sub=ittal, present risks which overshadcw the s=all doses associated with the controlled purge proposed by Metropoli-tan Edisen. Additionally, it should be noted that the syste= used at Oak Ridge is a s=all (15 cf=) syste= which would not be suitable for use at IMI. Although the cog =1: ant Oak Ridge personnel indicate tha: the current syste= could be scaled up, Me::cpolitan Edison considers that this scale up wculd require extensive engineering evaluation werk which would further increase the ti=e period required to place such a syste= in operatien. Oak Ridge personnel also questiened the prudence cf storing the Rryp:en-55 on site and could offer =o selution for ulti= ate dirposal of the gas. In s u==a ry, the solvent extraction precess was not censidered to be sufficiently developed to place into operatica at TMI in a ti=e f ra=e which would =ake the syste= useful as an alternate to the reactor building purge. 1741 122 e .-. wee ee e ese e e=e e se m.e -e =+ea- %e---e--- ee em

o ~. 2. Page 2, Section 1.4 paragraph 3. Provide a technical evaluation which support your statement that "there is no assurance that contain=ent integrity can be =aintained for the 2-3 years necessary to implement storage". Metrop:litan Edisen cannot guarantee certain=ent integrity in the long ter: due to:

1) The reactor building is not designed to be leak tight.
2) Leakage control is currently =aintained by keeping reactor building pressure negative relative to a=bient pressure so that leakage occurs into the building rather than from the building.
3) The nega-tive pressure in the building is dependent on reactor building cooling which cannot be assured.

'.t e reactor building allevable Technical Specifica icn leakage rate is 0.13 weight percent per day. The start-up integrated leak rate test indicated that the upper ccnfidence limit of taximum leakage was apprcxi=ately 0.095 weight percent per day. These figures shew that Icakage through the reactor building should occur under nor:al cen-ditions if a pressure differential exists. The negative pressure differen-tial can be maintained in the short term with the reactor building cooling system cperation. Although no calculatica can be =ade to deter =ine when the reactor building cooling fans (located inside the building) =ight fail, it is prudent and necessary to assume that f an f atlure will occur in the future. This fan failure is made = ore likely by the fact that the f ans are operating in a 100~ humidity environ =ent and that the fans are inaccessible for nor=al =aintenance such as lubrication. It sheuld be noted that the re-actor building cooling fans were caly required to be qualified (by speci-fication) for 3 to 4 hours of operatien in a 100*. hu=idity envirennent, and that the reactor building cooling fan =anuf acturer recc== ends lubrication of the bearings on a yearly basis. Due to the above qualification and =ainten-ance requirements, the reactor building cooling fans are already cperating outside their ner=al operating range. Since the reactor building is not air tight, it is reascnable to assume that a pressure buildup in the 1741 123

s 2. (continued) reactor building would cause leakage of Xrypton-35 gas fro = the reactor building to the enviren=ent. It is important to note that this c n occur without any detericration of the seals of the reactor building. Although seal deterioration is not a prerequisite for leakage frc= the reactor building, it is possible that the reactor building seals have deteriorated since the start-up integrated leak rate test. yurther de-terioratico of the seals would increase the leak rate and increase the dose consequences of uncentrolled leakage frc= the reactor building. High ;*.rypton activity in the nu=ber 2 personnel air lock has already been =easured. This activity in the air lock could indicate =inor leakage has already occurred frc= the contain=ent building into the persennel air lock. In additien, Metropolitan Edison has perfor:ed pre-li=inary calculations which shew that a very small inleakage of air into the reactor building is occurring. Upen reversal of the pressure differ-ential, Krypton could be expected to leak out of the building. Leakage paths which exist include equipment hatch seals, nu=ber 1 air lock seals, number 2 air lock seals, flanged penetratiens which use seal gaskets, valves, such as the large purge syste= butterfly valves, which are required to seat tightly at their seats, valves which use diaphrag=s to prevent leak-age around valve ste,=s, and other leakage which =ay occur through pene-trations and process systems. The above points justify Metropolitan Edison's lack of confidence that Ic.g-term containcent integrity can be guaranteed. A detailed tech-nical evaluation which could quantify the exact leakage rates and rishs of reaching those leakage rates is not believed to be feasible. .....,..,..-e e en = =* e- 'e

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' ) s t '3. Page 3, Item 4 disposal of Krypton-S$ in the Containment l 'dovever, it. the The NRC staf f realizes that Building is a prerequisite f or R3 deconta ina: ion. increases in staf f's epinion, the potential saf ety ha:ard and large coun:ered, radiation dese to the work force if delays in cleanup are en should be quantified. referenced in this section, Building is a pre-Dispesal of Krypten-85 in the Contain:ent l Delays in R3 deccatamina-requisite fer Reac:or 3u *l'.zg decentamina: ion.cannot be quantified without pctential safety hazards tha: tion represent The additienal I a better understanding of the actual core configuration. for reactor core deteriora-safety hazard arises from the increased potential The longer it takes I =ined state. tion the lenger the core re=ains in an unexa i the true state of the i to gain access to the Reactor Suilding and determ ne reactor pressure vessel, cere in:ervals and reactor pri ary coolant system, the ulti ste risk is for fuel, the longer the uncertainty remains as to wha: Even without further releases of radioactive nuclides frca the facility. is believed that purging the Reactor it this quantified risk, hewever, prudent path to disposal of Building of Krypton-85 represents the most The potential for delays represented i the Krypton-SS radioactive noble gas. additional risks of core deteriora:icn that by the other options represen: lding at:ccphere regardless of the magnitude, justify purging the reactor bui The true answer to this question cannot be determined, as soon as pessible. i ed tc the until the Kryp:ca-35 is disposed of and access is ga n in fact, Only then can the true safety' hazard and radiation dose reactor building. to the work force be assessed. It is not prudent to believe that the reactor j core will remain in a safe con'dition indefinitely. In addition to the safety hazard resulting from delay in cleanup in increased radiation-discussed above, delays in cleanup also vill result for the cleanup operation without The can-res exposure dose to the work f orce. Celays long delays has been esticated to be in the tens of thcusands zan-re. will subs:antially h represented by the alternatives to j urging the RB atmosp ere With addi:1cnal delays, increase this =an-rem exposure to the work force. 1741 125 e- .g . - ~ ~ .e =* . - =.... ~. mm. hmm.euge 6

s 3. Page 3, Ites 4 The NRC staf f realizes that disposal of Krypton-SS in the Containment Building is a prerequisite for R3 decontamination. However, in the staff's opinion, the potential safety hazard and large increases in radiation dose to the work f orce if delays in cleanup are encoun:ered, referenced in this sectien, should be quantified. Disposal of Krypton-35 in the Centain=ent Building is a pre-requisite for Reacter Building decantaminatien. Delays in R3 decontamina-tion represent pctential safety hazards that cannot be quantified without a better understanding of the actual core configuration. The additional safety ha:ard arises from the increased potential for reac:or core deteriora-tion the ?onger the core re=ains in an unexacined state. The longer 1: takes to gain acc ess to the Reactor Building and deter =ine the true state of the pri=ary cooltat system, reactor pressure vessel, core intervals and reactor fuel, the icnger the uncertainty remains as to what the ulticate risk is for further releases of radioactive nuclides frem the facility. Even without this quantified risk, however, it is believed that purging the Reactor Building of Krypten-85 represents the most prudent path to disposal of the Krypton-85 radioactive noble gas. The potential for delays represented by the other options represent additional risks of core deterioratien that regardless of the magnitude, justify purging the reactor building atmosphere as soon as possible. The true answer to this question cannot be deter =ined, in fact, until the Krypton-SS is disposed of and access is gained to the reactor building. Only then can the true saf ety' hazard and radiation dose to the work force be assessed. It is not prudent to believe that the reactor core vill remain in a safe con'dition indefinitely. In addition to the safety hazard resu' _.3 f ro= delay in cleanup discussed above, delays in cleanup also vill result in increased radiatica dose to the work force. The ran-rem exposure for the cleacup cperation without long delays has been estimated to be in the tens of thousands zan-rem. Celays represented by the alternatives to purging the F3 atmosphere vill substantially increase this ran-rem exposure to the work force. 'a'ith additienal delays. 1741 126

s 4 Page 6, Section 2.2. sa=ples, provide references to procedures used and other ( a) For current available documentatien that can serve as assurance for sa:ple data. Provide data to shew (b) No SE-39/90 sa:ple data is shewn in Table 2.1. that these isotopes were not present. Provide data to shcw that gross beta analysis were performed. No indication was given that shows that I-129 was sampled for. Reactor building air sa=pling takes place en a weekly basis using station procedure 1631.2. This procedure is used to routinely sa=ple for gas, particulate, iodine, and tritium. In addition, a gross beta analysis is performed en the particulate filter frem the sampling systes. Keactor building air sa ples have not been analyzed for Strontium-89/90. A method and procedure for perf orcing this analysis is currently being TMI. Upon verificatico of develcped thrcugh subcentractors working at this nethod, a reactor building air sa=ple vill be analyzed f or Strentium-39/90 and the results will be f orwarded to NRC. The gross beta analysis results on the reactor building air sa=ples are as fellcvs: TM2-2 Reactor Building i I Air Sample Gross Seta Analysis Sa=? e ID ';o. Cate of Saro.le Cross Seta Error + l y Ci/cl Ci/=1 24456 11/8/79 2.27 E-9 1.40 E-10 24459 11/8/79 8.98 E-10 1.04 E-10 27S88 12/20/79 1.78 E-9 5.44 E-10 27889 12/20/79 1.55 E-8 1.33 E-9 28361 12/23/79 4.77 E-9 8.77 E-10 23437 12/28/79 5.24 E-8 2.4S E-9 I The above gross beta results indicate that very little Strentiu=- 89/90 is airborne. I741 127 em o es e amm e. e e e e e ma ee <mweem me e = ee e e e eem e e e. een ee w .-.eem. ese e ,e - ^ d Mmea >+wem W 4 + - - -

s t 4 (centinued) Metropolitan Edison has not analyced a reactor building air sa=ple for Iodine-129. Calculations have been perforced which show that Iodine-129 in the reactor building at=osphere, if released at the rates conte = plated for the controlled purge progran, would remain less than the allowed un-restricted area MFC off-site by approxi=ately a factor of ten. This cal-culation assumes a 100% release of the core inventory of Iodine-129 and Tellurius-129 into the reactor building and a partitioning of these iso-tcpes such that 60% re=ains airborn and 40 is dissolved in the su=p water or plated out. The analysis also assumes that meteorological con-ditiens specified in the Technical Specifica icns occurs, although Metro-politan Edison intends to release the reactor building at=osphere only under conditions of favorable meteorology which provide =uch more dilution than that available from Technical Specification meteorolegical conditions. Due to the abcVe, Metropolitan Edison does not currently intend to sa=ple the reactor building ateosphere for Iodine-129. I741 l28 e F a m. m = Nee o

4 5. Page 6, sec:fon 2.3. A continuing sampling program should be in place to assure that the cost recent data base is available. Metropolitan Edison has a weekly reactor building at sphere sampling progra= in place at I?E. This weekly sampling has provided a large data base which is currently being catalogued and evaluated by Metropolitan Edison. Upon ec=pletion of the evaluation, Metropolitan Edise-intends te docu=ent the sample data in a :echnical data report. This :echnical data report will include all sample results since March 2Sch and should be available in February. Although this technical data report has not yet been formally documented, Metropolitan Edison has thercughly evaluated information available to date and has concluded that the reactor building air sa:pling results substantiate the contention that negligible off-site doses and radiological i= pact will occur as a result cf the preposed con-trolled reactor building purge. ) l2h 9 Moe me e e e e m e .,e e e-me e .-.+e

6. General Co==ents on Section 2. No information was provided on the relative humidity on R3. High relative humidity condition can cause problers in the HE?A filters regardless of the disposal methods used. Since there are no heaters upstream of the HEFA filters, provide an evaluation as to the poten-tial problems of coisture on the HEPA filters and what will be done to handle this problem. Table 2.1. (a) No sa=ple provided since Septe=ber 1979. (b) No gross beta analysis given. (c) Sr-29/90 results not included. Provide information relative to (a), (b), and (c) above. Upon verifying that 100% hu=idity existed in the reactor building, Metropolitan Edison conducted an evaluation of the ef fect of this high husidity on performance of the HEPA filters in the reactor building purge system. The evaluation perfor:ed by Metropolitan Edison shows that moisture forzation on the filter media and the filter plenu: and housing walls would only occur if the temperature of the surfaces was below the dew point of the air drawn through the pienez. These te:pera-tures can be suf ficiently elevated to ensure against moisture formation in the filter housing through the application of external heat. Metro-politan Edison intends to add external heat through the addition of five electric infrared type radiant heaters alcag the outside of the filter plenus. Metropolitan Edison will have heaters in place and operable to ensure that moisture for ation does not decrease particulate re= oval efficiency of the HEPA filters during reactor building purge. See the answer to Question 4 above for the answer to the remaining questions raised in Question 6. 1741 130 eO /

L V{ 4* ~r f5 7. Page 10, Section 3.1, Paragraph 1. l,4 j " radioactive Provide a discussion as to what you mean by the statement, vent stack at tires when wind and p; gases will be released f rc= the plant favorable for at= aspheric dis-I.; other metecrological conditions are =ost persion. The controlled purge of the reactor building at=asphere will be conducted in a canner that provides for variable ficw rate of the purge e system frc :ero to 1000 cf: depending en the radioactivity level of the j['b: u, A seteoroicgical released gases and the site seteorological conditions. of wind speed, monitoring program is in place which allows hourly input wind directicn and tc=perature differential with altitude. These para- [ =eters are used to calculate each hour in advance the atmospheric disper-9 sion of the plant vent stack gas release to the envircament surrounding 7 the plant site in accordance with Regulatory Guide 1.111 " Methods Tor ( Estimating At=espheric Transport and Dispersion of Caseous Effluents in P Routine Releases Frc= Light *n'ater-Cooled Reactors." The purge flew rate r will be 102ited in each hour so that the peak off-site beta activity does not exceed 0.1 mren/hr. As shown in table 5.2-5 cases 19 and 21 for typical October and Novemb er meteorologies, the total peak off-site beta skin dose k k is on the order of 5 mrem for co=plete purging. Il I 1741 131 .t. y .ij 1r ot t 4 I t i 6 I f

b 8. Page 10, Section 3.1, Second Paragraph. (a) Provide a description of the modifications needed to reroute flow from the inlet of the supple entary vent filter to the plant vent. (b) From where is AH-v36 controlled? (c) Where is flow rate, te=perature, and radiation level sonitored during discharge? (a) The ficw frem the inlet of the supplementary filters to the plant vent will be rercuted in the following steps:

1. Reco==ission the auxiliary building, fuel handling building, and hydrogen control purge systes filter trains.

This in-cludes ANSI N510 testing of the filter trains,

2. Calibrate and reactivate stack acnitor EPR-219A.
3. Secure the supplementary filter train b;. turning off the supplementary f ans and closing the isolation door f rom the stack inlet plenum to the filters.
4. Uncap the stack by removing the existing cap.

(b) AH-V36 is being nodified to allow re=ote control of the valve f rem a location in the southeast corner of the auxiliary building on the 328' level. The control station is located behind the shield wall just north the stairway frem the 305' elevation up to the 328' elevation in the southeast corner of the auxiliary building. Sound power phone communicatiens will be provided f rom th'is rc=ote control location to the control room. (c) Hydrogen control purge syste= flow rate and temperature are measured at the discharge of the hydrogen control fan and monitored in the control room on panel 25. Radiation level is =onitored in the filter housing and read out at a local readout station near the filter housing en the 328' level of the auxiliary building. General area radiation icvels around the filter housing area vill also be monitored by local radiation monitor HP-E-3236 1741 132 ......g. +

3. (continued) (c) (continued) hich ill be located near the hydrogen control filter plenu=. This area radiation =onitor has a local readeut and a re=ote readout in the centrol rocs en panel 12. It should be noted that general area radiation levels in the s vicinity of the filter housing are not expected to appreciably increase during reactor building purge. 1741 133 e

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+ F,- - 7 -ge high,what impact see the answer fer Question 6 for steps bein? taken to Fid"*^2 c,3 No te 3-d e-- *E -pe a on of tne ns..s seisture buildup., rom a,,e -" system eperation is expected due to 4 -a * -e other adverse ec:ec - - e air. of the reactor building exhaust ,he, 0 0...,,.. l 2 4 >. [h 9 I i 3 k I J k I I, i e - -. ~ ~ ~ _,. - - - - _ _ _ _ ygan d HHO e

4 10. Page 12, Section 3.3.1, HEPA Filters. Provide a co=mitment to in-place test the HEFA filters in acccrdance with ANSI N510. Metropolitan Edison has ceraitted to in-place test the HE?A filters in accordance with ANS1 N510. The preposed Technical Specifications for Unit : currently under review by the NRC ccntain the following language under surveillance Require ent 4.6.4.3c. "The hydrogen purge cleanup system shall be demonstrated operable after each complete or partial replace =ent of HEPA filter banks by verifying that the HEPA filter banks renove greater than or equal to 99.95% of the DCP hen they are tested in place in accordance with ANS1 ':510-1975 while operating the syste: at a flow rate of 1000 cf: - 10%." l74i 135 9 s

.[ 11. Page 12, Section 3.3.1, Last Paragraph. Previde infor=atien as to the type of i=pregnate for the charcoal adsorbers. Since there is essentially no iodine in the contain=ent at=csphere, why is it necessary to use charcoal adsorbers? The charcoal filters in the hydrogen control purge filter train are i=pregnated with tertiary a=ine co= plex and potassica iodide by Nuclear Consulting Services of Colu= bus, Chio. Metropolitan Edison agrees that there is essentially no iodine in the centain=ent at=csphere and that it is not necessary to use charcoal adsorbers. Metropolitan Edisen believes, hevever, that no detri= ental effect accrues frc= the use of charcoal filters in the purge train. -e have already replaced the charcoal and i vill be in service during purge. 1741 136 f 1 i l ,I 6 I

13. Page 13, Section 3.3.1, Third Paragraph. Provide the location of Panel No. 25. Panel No. 25 is located in the control roc =. 2.is panel is the control and ncnitoring panel for the reactor building nor=al ventilation and purge syste: and the hydrogen control purge systen. 1741 137 ..m. ~ .~p ~.. -

== Page 13, Section 3.3.1, Firs: Paragraph, First Sentence. 12. Previde a description of the fire detection syste= in the filter hcusing. The reactor building hydr: gen control purge filter ::ain is provided with a deluge water spray syste: in accordance ith NFPA-13. A ta=pera-ture sensing detector in the filter housing in the vicinity of the char-coal filter autecatically operates the deluge syste:. An alar = is sounded in the centrol rec: and locally coincidental with operation of the deluge system. h Y .m,- ..e

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.~ l!.. Page 15, Sectica 3.3.3., First Faragraph. Provide a description of the radiation =enitor. HP-R-227 is a sa=ple panel, not a radiation =enitor, which allows direct sampling of the reacter building at csphere. S.e sa:ple panel can be used to fill a sa:ple bc:b for gas analysis, to perfer: a par-ticulate analysis by drawing centain=ent air through a filter, or to perform a tritiu: analysis by using the installed bubbler. n.e a:: ached syste= sketches provide details of the sa:ple sys:c=. 1741 139 m .e e me =.. - .eeme. e-e -p. ee= --..-ee O

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15. Page 15, See:icn 3.3.3, Se end Paragraph. ' Jill gress beta analysis be dene? If not, jus:ify the reasen why 1: vill not. See the answer provided for Questien '. Nring purge, particulate sa=ples will be analy:ed fer gross beta. 174F 142 ,oe a.eamo s, yo e o - om-am o e

16. Page 15, Secticn 3.3.3, Third Paragraph.

  • 'ill AH-V7 be throttled to centrol the flow of replacement air in the a

?27 If not, how will this flow be contr:11edi AH-V7 vill not be throttled to control the flew of replace ent air :o the reactor building. Upon c:=:encement of reactor building purge, the reactor building will be a: a s=all negative pressure relative to the auxiliary building. This s all negative delta pressure vill cause air flev from the auxiliary building into the reactor building through the AH-V7 replace:ent air path. The flew from the auxiliary building to the reactor building through this path will cause a tendency for equali:ation of the pressures in the two build-ings. Hewever, the flow re=cved frc= the reac:or building by the hydrogen control purge f an is expected to =aintain a very s=all nega-tive pressure in the building, without thre:tling of AH-V7, so that flev vill centinue f rom the auxiliary building to the reactor building. If Krypton-85 should go frem the reactor building into :he auxiliary building, existing radiation monitors in the auxiliary building would detect :he Krypton-85 in the auriliary building and alars in the control rec =, By procedure, this alars in the auxiliary building vill require shutdown of the targe until the cause of the alar = is investigated and understood. If this flew of Krypton-SS cecurs into the auxiliary build-ing, the auxiliary building ventilation system vill remove the Krypten-85 and discharge it to the stack so that the end result of this leakage vill be a discharge of the Krypton-SS through the stack. Although AH-V7 is not throttled and is not controlled from the control roem, the ianer centairment isolation valve AH-V3B can be shut from the control rocs if Krypton-35 leakage into the auxiliary building is suspected. e 8 - eu -ee .....==e.

  • m.=

- -.... - - = = = = * --m = e e .e.. ..==.e==-em-. ' - - - = - - - 7 g

17. Page 18. Section 3.10, Ite: No. 7. ill this ga==a menitor alar: :ause the exhaust fan to : rip? The filter housing ga==a conitor probes will not alarm or cause the exhaust fan to trip. The ga==a =enitor vill be conitored frequently, and by procedure the reactor building purge would be ter=inated if con-tact readings on the hEPA filter reaches a level of I re= per hour. It should be noted that the i re: per hour upper 11=1: i= posed on the REPA filter contact reading is an ad=inistrative limit which has been imposed by Metropolitan Edison as a precautionary reasure only. If radiatien levels higher chan 1 res per hour on contact with the HEPA filters occur, radiation exposure to workers during fil:cr changccut should still be relatively s=all. Filter changeout can occur at higher radiation levels on the filter surface, therefore strict alarm and shutdown ceasures for this reading are not required. 17L41 144-

e 15. ?sge 18, Section 3.10, ::e= No. 8. '"na: is the range of the HPR-229? HPR-229, hich is the radiatien monitor cc the discharge of the hydrogen control f an is being modified to allow reading of F,rypton-35 up to 1000 microcuries per cc. This codifi:a:icn is being a:cc:plished under an EO! a: TMI. r-1741 143 g

19. Page 24. Section 4.2. This secticn should be, revised to reflect the lici:ing conditions of operation set for:h in NURIO-O'.72 Standard Radioicgical Effluen: Technical Specifica:icn far ?'Gs. Addi:1cnal guidance en implementa-tion of Appendix 1 to 10 CFR Par: 30 and 40 CFR 190 is given :o NUREG-0133. Although NUFIG-0472 " Standard Radiological Effluen: Technical Specifica: ions for ?'a*Pa" has no: been 1 cerporated into the Inviren: ental Technical Specificaticas for TMI, this standard is consistent with the dis-cussion of 10 CFR 20 and 10 CFR 50 App. I given in Section 4.3 and 4..'. of

he Reactor Containment 3uilding Arcosphere Cleanup Report.

1741 146 3

t 20. Page 27. Sectica 4.5. Since Appendix I dose design objectives are stated in terms of quarterly and annual values, it is clear hev you in:end to li:1 the releases to assure that these design objectives are no: ex:eeded. Provide a dis-cussion as to how you intend to implemen the requirenents of 40 CFR 190 including the contribution f ro: direct radiatien. 10 CFR 50 Appendix I addresses quarterly release limits in See:ica IV. A such that if one-half the design objective annual exposure is exceeded in any calander quarter, the licensee shall investigate, take corree:ive actien, and report to the NRC.

  • 'e do not believe that the purge operation vill a

exceed one-half the annual design objec:ive exposure of 15 millire: skin dose. Theref ore, we vill be within the quarterly allevable li=it for 10 CFR 50 Appendix 1. If the allevable conditiens of Section IV. A are exceeded, then the required corrective ac: ion and reporting vill be co=pleted in accordance with this section. 40 CFR 190 requirements on direct radia: ion in paragraph 190.10 (a) limit the annual dose equivalent to 25 millire=s to the whole body, 75 tilli-rems to the thyroid, and 25 =illiress to any other organ of any ce=ber of the public. These limi:s are greater than the limits allcwed under 10 CFR 50 Appendix I. I741 147 e g

i 21. Page 69, Section 8.1, Paragraph 1. Provide an analysis to justify the st atement that "the risk to the entrant are quite high" if the contaia=ent is not purged prior to entry. Metropolitan Edison is still conducting experi=ents through various penetrations and the air locks to quantify the exae: exposures that would occur inside the reac:or building. Upon ec:pletion of all these experi-cents, data gathered will be evaluated and hazards posed by the Krypten-35 a:nosphere will be thoroughly evaluated. It can be stated that radiation exposures as lov as reasonably achievable can only be acco=plished if the radiation exposure associated with Krypton-SS is eliminated prior to entry. Although the additional exposure caused by Krypton-85 should not cause significant risk to the entry team, assu=ing that all beta doses are shielded through the wearing of protective clothing, analyses have shown that a signification portion of the whole body dose associated with :he reactor building entry prior to purge comes f rom radiation associated with the Krypton-85 in the atmos-phere. Risk to the ent ry team does exist, however, due to the potential for accidents which ceuld cause loss of suit integrity. Tearing the protective clothing.or removing the face mask (inadvertently or due to loss of breathing air) would cause addi:ional skin and internal exposure. Metropolitan Edison has recently condue:ed experi=ents through pene-tra: ion R626 designed to determine the ef f ectiveness of clothing =aterial to be worn by reactor building entry tea: =e=bers. The results of this experleen: are not yet co=pletely understood, bewever, they do show that the caterial is apparently effective in rencving dose contribution frem betas e:itted by Krypton-85. The =aterial did not, however, prevent

he Krypton-SS f rem penetrating the =at, rial and con ta=inating the TLD case and chip wrapped inside. Also, seme of the real time radiation measurement instruments were apparently af fected by the presence of the Krypton-35 clou& making their readings inaccurate.

1741 148 .. ~ -

2: (continued) Present sa=plin;; indicates the concentraticn of Krypton-SS in the ~MI-2 contain=ent building is appr ximately.8 ?Ci/cc. Without any protective clothing, the resultant dose rate to the skin is calculated

o be 160 re=/ hour. With protective clothing to reduce beta dose (10 protec:icn :.1.5 =m tissue equivalen: :aterial), the skin dose rate can be reduced to 1.6 rez/hr.

The whole body dose rate with or without protective clothing would be calculated at 1.6 rem / hour. This dose rate would limit stay time to approximately 108 minutes to stay within the 10 C n 20.101 dose limits assuming no other radiation source. 1741 149 o e me. w =e.e e e=* ee e .-we ..e4e N ....-..e

== -- w

22. Page 69, Section 8.1, Seccad ?aragraph. Provide or define in greater detail poten:ial release points frc: c ont a i:.nen t. See the ans er provided in Question 2. 1741 150 e ~ t-

23. Page 69, Section 8.2 Current ';oble Cas Activity Provide in the design basis consideration for particulates, H-3 (Sr-89/90), and Iodine. Section 5.1 includes an analysis of allevable purge rates for the par:icula:e CS-137, and Iodine-131. These analyses demonstrate tha: the Iodine and particulate contents are far belo the K ypton-SS in terms of limiting flow rates to =ee: 10 CFF. 20 Appendix 3 lici:s. Therefore, the system design basis does not address these potential radioactive isotopes. Sr-89/90 is addressed in Question I.. From the gross beta activity ss=ples, it is not expected that airborne Sr-89/9') represents a sufficiently high con-centration to be considered in the syste=s design basis f or the non-purge alternates. Preli=inary assessments of tri:iu: level in the reacter building atmosphere indicate that tritius activity is sufficiently below Krypton-85 activity that tritiu: need not be considered in the design basis for the alternate syste scoping studies. I: sheuld be pointed out that from the standpoint of purging the reactor building atmosphere Krypton-35 is by f ar the dominant controlling isotope for determining acceptable purge flow rates and expected of f-site dose censequences. If in the develop =ent of final designs for atmosphere storage options additional isotopes need to be considered, the effects will be to add additional complexity, costs, and -t i e which all tend to =ake the purging option even more f avorable. 1741 151 3

24 Page 70, Section 8.2, Contain=ent 'lo lu= e. If perfect =ixing is not achieved, what would be the =axi=u: 'e clu=e to be processed? he process volu=e is calculated based on perfec: =ixing of a con:inuous feed and bleed process to provide ulti= ate dilution of Kryp:en-SS -5 f rce 1 a Ci/=1 to 1 x 10 /Ci/=1. The average rate of change of concentration within contain=ent can be written as: dC F) - - C x ((V) de where: c = containment concentration,pCi/=1 F/V = Fraction of containment volu=e re=cved per unit time F = Discharge flow rate V = Contain=ent volute t= ti=e This expression has the solution F --t C = Co e v k"nere Co is the initial concentration of 1p C1/=1 For a final cen- -5 centration of 10 v C1/=J h = 10-5',,~ht, for perfect mixing. ior less than perfect =ixing, we can int roduce a =ixing f acter, MF, such that W is the ratio of peak concen: ration to average concentration and C, the li=iting concentration is given by C -F L -5 -t - = 10 = 11F e v Co k'here MF 31. Solving for 3, the nu=ber of containment vel =es to be processed v - = Im 105 + 'm MF Ft v 1741 52 = 11.5 + 6 MF For perfect =ixing, M7 = 1.0, ?

24 (continued) El = 11.5. ~ v For a =ixing f actor as higL as five, or a peak cencen: ration as high as five tines the average concentratien, the process volume increases 11 - 11.5 'l.6 = 13.1 v 6 or, additional processing of 3.2 x 10 cubic feet. For the purse eption, this increases the process ti=e by 2.2 days. The integrated dose conse-quences would be unchanged. For the process and storage optiens, the cc:pressics storage volu=e increases by 14: and the charcoal stcrage velu=e increases by 14?.. The cryo-genic storage volume shculd be unchanged, be:ause the total Krypt:n-85 conten: renains the same. 153 e 9 e . ~. L-

25. Page 70, Section 8.2, Seis=ic resign Category. Provide justification for the state =ent that considered appropriate for the situatica atRegulatory Guide 1.143 is not DC -2. Metropolitan Idisen censiders regula:cr/ approval to s:cre the Krypten-85 in a vessel which is designed to less stringen: require:ents than the current vessel, i.e. the centainmen: building,is not likely to be obtainable. As a result, Metropolitan Edison has concluded that at least the storage syste=s for the Kr/pten-83 would be required to meet seismic Category I and ASME code, Section III Division 1, Class III require =ents. Since Regulatory Guide 1.103 impeses less stringen: re-quirements en gaseous radioactive vaste treatt:en: systems, Metrcpolitan Edison concluded that it would not be prudent ' to invoke only those re-i l quire 'ents on the design of these syste=s. Also, the hydrogen control purge syste= is a safety grade syste which does meet requirements more stringent than those imposed by Regulatory Guide 1.143. I In the answer to Questions 30, 32 and 33, Metropolitan Edison did look at other ddsign requirenents for the alternate systems. The investigation of the time and seney required to install these sys-te=s for the various design require =ents scenarios showed that the imposition of require:ents more stringen: :han Regulatory Guide 1.143 did not significantly impact the amount of =eney or time required, and therefore, was not a major factor in decisions to use the purge rather than any of the alternate systems. If controlled venting is deter ined to be unacceptable, then the design alternatives for R3 atmosphere cleanup should be of sufficient in-tegrity that inadvertent release is prctec:ed against over the expected duration of storage. This has been the basis for selection of the design criter!a for the alternatives examined. This basis vill require more stringent ccaditions than provided in Regulatory Guide 1.143. 1741 154

26. Page 70, Section 3.2, Design Code.

  • 'e do not agree that Regulatory Ouide 1.143 is inappropirate for the design of alternative systems..rovide further justification :o suppor:

your positica. See the ans er provided to Question 25. 1741 155 ... ~... - .g . -... ~

a 27. Page 71, Section S.2, Char: cal Adsorption. Provide an analysis to show :ha: it will take 11.5 ti es :he rea::or building a =csphere volu=e to achieve MFC levels. See answer to Ques:icn 24. 1741 156 S g

28. Page 71, Section 3.3, Charcoal Adsorption. For the Adsorption and Storage Sys:e=, where would the interf ace point with con:ai=ent be? ""he interface point for all the systems (cryogenic treatment, gas compression and charcoal adsorptica) is the hydrogen control purge duct, after the centai=ent air passes thrcugh the hydrogen control filter train. In other words, the existing HEPA filter sys-tem would be the same on all systems. 1741 157 / g t.r

29. Page 71, Section 8.3.1, System Description. Provide the basis for the 34,000 tons of charcoal sta:ed in this section. Provide justifica: ion as to why it is ne:essarv to design and construe: the tanks to Section III, Class 3. 6 Sufficient charcoal is required for processing 23 x 10 cubic feet of centainment gas without the occurrence cf " break-through," i.e., without detecting signification Krypton-83 at the exit of the charcoal beds. From the 12th AEC Air Cleaning Conference, NE00-12327, " Measure =en: of Dynamic Adsorptica Coef ficients f or Noble Cases on Activated Carben," D. P. Sierwarth, et. al., break-through occurs at se=e fraction of the can residence ti=e, , of krypton in a charcoal bed. This is illustrated in enclosed Figure 10 from SEDO-12327, which shows the ratio of bed cutput ac-tivity to bed input activity as a function of time, given in di=ensienless units of t/t m The value of t in turn, is given by: m d t = m F b'h e re : e = mean residence time, minutes s K = the dynamic adsorption coefficient for noble gas on charceal d cc ? sep/gm M = mass of charcoal, gm F = carrier gas flow rate, cc/=in Frem Figure 10 of NEDO-12327, the time to " break-through," t b' is on the order of 0.7 t m b = 0.65.t,: Using a minimal amount of conservatism, let t

= 0.65 Kd*M F

This expression is used to determine the required charcoal mass. 1741 158 2-

12th AEC AIR Ct EANITJG CONFERE:JCE 1.0 - 1 ~ i ( N g :a. 0 0 Xe,77 F Xe,77 p o 12 Col. Diam = 1 1/4 in. Col. Oism = 1 1/4 in, u = 3.2 f t/ min u = 0.8 f timin I = 240 min t = 95'; min m m s 0.7 1.0 1.3 0.7 1.0 1.3 t/t t/t m m (b) 1 ls) 1.0 - a t r f eN l Xc. 0* F 0 Kr,77 F Co!. Diam = 2.in. C Ccl Cism = 2 i i. u = 0.0 f t/ min u = 0.8 it/ min o tm " 2DM min t = 130 min O m j e i 0.7 1.0 1.3 0.7 1.0 1.3 o 9 t/t 1/fm m (d) (:) - Theoret: cal ?

2. r ;.imen t a!

FICUnE 10. CA LCUL AT CD VCnCUS CXPC A; MENTAL SnCAKTlinOUCll CURVCS ./ 1741 159 3 de

e 29. (Continued) Convert the expression to more eenvenient units, i.e., express M in tons of charcoal and F in scfm. Theref ore : [g/ ton) ( 0.65 x K x M x 907.2 x 10 d g, 4 F x 2.832 x 10 {cc/ft3j 20.8 Kd* F Or, Fxt b d " 20.8 x Kd 6 3 Fxt equals the total pro:essed volume of 23 x 10 ft Therefore: 6 23 x 10 ~ 20.8 x Kd 1.11 x 10 tens d The supplier of the Oyster Creek charcoal system indicated that the value of K f r Krypt a using a e al base type of activated d charcoal aperating at ambient te:perature is 33 cc/gs. Therefore: M = 1.11 x 10 33 33,500 tons a 34,000 tons = Also, the density of the char: cal used at Oyster Creek is 34 pounds per cubic foot. Based en discussiens with a charcoal nanufacturer, this represents an upper limit to the charcoal density whi:h can be achieved by careful loading of the charcoal centainers. I741 1/:0 Accordingly, the charcoal volume is: i i .I 3

29. (continued) 34,000 x 2,000 ,, = 34 2 x 10 cubic feet = The charcoal storage tanks would be designed to =eet ASMI Section III, Class 3 require =ents in accordance with Table 1 of Regulatory Guide 1.143. Since these tanks would house Krypton-85 for an indefinite time period, it is felt that the design cf these tanks should be consistent with the existing centaia=ent vessel. As indicated in the re-spense to Question 25, Metropolitan Edison did lock at other design re-quire:ents including both less stringent and mere stringent r e quir e=en t s. The impositien of less stringent design require =ents did not materially affect the cost or schedule for impicmenting the alternative stcrage options. 1741 161 3

30. Page 73, Section 9.3.3, Cos and Schedule Estimate. Provide a detail breakdown to justify why it will take 30 to 40 =anths to design and construct this system. In order to evaluate the effor: required :o place the alternate syste=s into operation, Metrcpolitan Edison perf orced a scoping evaluation which included a preliminary system design for each alternate. These pre-liminary sys c=s were then evaluated by Metropolitan Edison's architect engineer to determine schedule and costs for implementing the sys:e=s. The schedule deter =ined is as sho n in the at: ached bar chart. Our architect engineer used s:andard industry estimating and scheduling techniques to de-termine the ti es and costs presented. The cost and schedule esti=ates are based on years of expe; 'ence and considered judgement and are censidered adequate for use by Metropolitan Edison. A more detailed estimate would require greater design detail, which would i= pose additional, unwarranted delays in solving the Krypten-85 problem. In order to co:plete the cost ar.d schedule estimates, the ar-chitect engineer assumed as a base (or most probable) case that the build-ings, equipment, piping, supports, and electrical service were seismic Category I and that the piping design code was ASME Section III, Division I, Class 3. The reasons for these assc=ptions are presented in the answer to Question 25. Additionally, shortest schedule / leas: cost and lengest schedule / =aximum cos: estimates were also made. For the shortest schedule evaluation, buildings, equipment, piping, supports, and electrical service were non-seismic, and the piping design code was A.NSI B-31.1/ASN2 VIII. For the longest schedule evaluation, the same seismic and code requirenents as used for the =ost probable case were used, but aircraft hardening for the building was also assu=ed. In each case, the schedules and costs are considered to be the additional time / cost required for the alternates as campared to the base case of perfor=ing a controlled vent of the containment. 1741 1A2 g

PRELittillARY SCllEDlli E T ll!E (flottflis) O 5 10 15 20 25 30 35 40 45 DESIGli e o gj) _..._____g t) (. Pit 0CUREllEllr o l'j (J Ill.DC. ERECTIO!! c' e i

f. I.

EQl'r. If3STALLAT10tl

  • c' "o

$ i}. TESTlt1G .o-O COllPL PURGE n _ _ _ _. _ __._ q tangy nnnu / 't.KTL Fe rHSH I h DESICli g e I'ROCultEMEttr g T e T Bl.DC. ERECT 1011 [ g-j - t.je EQl'r. IllSTALLATIO!I

  • e e

TESTltK O' - e COllPL PURCE O-- - - - - -0 T DESIGli o g g Pit 0CUllEtIE!Tr G }' y <gh IlLIX;. E RECTIOII

  • e

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30. (continued) The f ollowing additienal qualifications apply to the schedule and direct cost esti=ates for all the alternative systa=s: o All buildings are located at grade level. o All structures are assu=ed to be located approximately 1,000 feet fro the contain=ent. o Intercennecting piping fer contain=ent at=csphere frc= the power plant to the syste= will be buried and encased in concrete. o Cost of charcoal /HEPA filters are excluded since they are co==0n to all systems. o All costs associated with the f ollowing items have been excluded fre the esti= ate. - Securi'ty - Fire Protection - De=olition of f acilities and salvage of equipment upon de-mobilication of syste=s. - Major site work (excavation, backfill, etc.) Operation and =aintenance of syste=s. - Licensing - Permits, fees and insurance. - Disposal of radioactive =aterials. o Schedule is based en industry standards for lead ti=es and con-struction methods and has not been opti=ized. o Power supply will be frc= existing equip =ent in the plant. o All estimated costs are in present day dollars (Septe=ber 1979). o All allowance for contingency is included at 33 percent. Sk 2

s 30. (centinued) For the cryogenic system, the following addi:1onal qualifica:icns apply: o Ces: for existing equipment procure:ent is for the specified equipment (Specification 3031-M-95) delivered to :he TMI site in operating condi:icn. o Crjegenic equipeen: will be previded en skids vi:h valves, centrols and instrumentatica included. o Product cespressor is included with the existing equipment. o Instrument air will be provided f ree local ec= pressor, o Cooling water and de=inerali:ed water will be provided f rom existing equip =ent in the power plant. o The utility costs are for operation phase only. Cens:ruction and start-up utilities are ex:luded. For the gas cc:pression system, the following additional qualifi-cations apply: o 36-inch pipe wall thickness is 3/S inches. o Pipe will be supported by a structural steel grid system. o Pipe will be run in 200-f oo: leng:hs, capped at each and inter-connected with 4-inch pipe. For the charcoal adsorption system, the following additicaal quali-fications apply: o Tanks will be supported by building floor and roof truss system. o Tanks are arrangod in 45 rows of 10 and are not staggered as shown in sketch, o All valves will be manually operated at the valve. o Tank orders to be issued to several vendors to opticice production time. [) o Charcoal will be available at jebsite as required fcr construction. o Cost of storage and handling of charcoal at jcbsite is excluded. o In all cases (least cost, mest prchable cost, and =aximum cost). S61.2 million for charcoal is included in the cost of components. t

30. (continued) It should also be pointed out tha: only direct costs were she n in the original submittal. Since cost considerations were not the =ajor determining f actor in rejecting the alternates, other costs such as re-place ent power and revenue losses were not included. Metropolitan Edison did, however, evaluate all costs associated with implementing the al:erna:ive syste=s. A tabulation of all these costs is a:tached. The f ollowing addi-tional qualifications apply to these = ore detailed cost esticates. o An escalation alewance of 7\\ per year compounded has been provided. o AFUDC (incre= ental) of 1 P. per year ec= pounded has been used. It is assumed the plant will be cc :issicned in 42 =cnths af ter the working en:ry. o An allowance of $10 million per =onth has been included for replace- =ent power in 1979 dollars and has not been escalated. o Credit for fuel has been provided at the rate of two = ills per K'JHR based cn historical fuel cycle costs. Plant rating of 959 MWe, along with 60 capacity f actor, has been assu=ed for this calculation. Fuel costs are 1979 dollars no: escalated, o Differences in O&M costs have not been evaluated and are not considered to be significant at this time, o Loss of revenue due to TMI-2 being out the rate base is $8 million per month. This includes capital cost, depreciation, incase tax, operations and =aintenance costs and other taxes. 1741 ie:6 e y

I The resultant cost euttmate ($ millions) for the cryogenic treatment system are: 30. (continued) Additlonal iteplacement Fuel Revenue Components Building Utilities Escalation AFUDC Power Cost 1.os s Total 1 Least Cost 5.2 4.8 0.4 0.6 7.0 200 (16.7) 160 361.3 1 1 2 Flost Prob. Cost 5.7 5.0 0.4 0.9 8.0 250 ( 2 0. 11 ) 200 449.2 3 Itax. Cost 5.7 7.2 0.4 1.3 10.4 300 (25.0) 240 540.0 i 1 2 3 Twenty months Twenty-five months Thirty montha l t i ,f The resultant cost estimates ($ millions) for the gas compression system are: I j Additional Replacement Fuel Revenue Components But1 ding, Utilities Er.calation AFUDC Power Cost Inss Total Leant Cost 43.1 12.4 4.3 40.3 250 (20. t!) 200 529.3 ttost Prob. Cost 53.6 13.0 6.3 52.0 3"O (25.0) 240 639.9 tiax. Cost 53.7 26.2 8.9 67.0 350 (29.2) 280 756.6 Twenty-five months Thirty months Thirty-five montha lN fA p The resultant cost estiaates ($ millions) for the charcoal adsorption system are: i '~ Addittonal lleplacement Fuel llevenue q Components Building Utilities Esc.ilation AFill!C l' owe r Cost 1.on n Total Leaut Cost 107.6 20.9 12.2 100.3 300 (25.0) 240 756.0 !!os t. Prob. Cost 117.0 22.0 15.4 116.4 350 (29.7) 7ttu !!/1.6 i tiax. Cost 3 117.3 42.2 20.4 143.2 400 (33.1) 320 1009.8 I y 4 'Thtrt: montha Thi rt y-f ive Forty nontho

31. Page 76, Sectico S.4.1. Provide additional details en the Cenpression and Storage Syste: evaluated. Provide interf ace inferna:icn. For interface information see the responses to Question 23. A more detailed cos: and schedules breakdown is given in the response to Questien 30. The conceptual design of the Cc=pression and Storage Sys:e= is shewn in Figures S.4-1, 2, and 3. The Design 3 asis for :his sys:e= is given in Section S.2 and is the same as for the c:her al:erna:e systems. Additional details of the evaluation of selected storage pressure, re-sulting s:orage vole =e, and length and veight of storage piping are given belev. Finally, details of the shielding evaluation are provided. As a first approximation, the high pressure storage system which would be most economical is the one which contains the smallest weight of metal. Accordingly, the effect of the main system variable, i.e., storage pressure, on storage vessel weight was evaluated as follows. For a c ntainer initially filled with air at atmos-pheric pressure, the storage volu:ne recuired is: P O V = V x S P P 1741 16.8 o g

31. (continued) Where: recuired storage volume, ft' V = S 6 3 23 x 10 ft processed volume = V = p 14.7 psia P nitial container pressure = O storage pressure, psig P = 6 23 x 10 x 14.7/P Therefore V = S The required container wall thickness, t, is given by: PR t = 0 Where: container radius, in R = allowable stress, psi o = 15,000 for a typical carbon. steel = in accordance with the ASME Code, Section III, subsection NA Neglecting the steel contained in the container ends, which is reasonable for containers such as piping with high length-to-diameter ratio, the total container stee2 volume (V ) is: O

  • b*

V O container length, in Where L = 3 recuired container volume, in = -volume per unit length 6 23 x 10 x 14.7_ 1728 X = P 2 nR h e 9 -*-m w --- g

31. (continued) Accordingly, using t = PR/c 6 23 x 10 x 14.7 x 1728 PR 2Rx x c-V = 0 P:R' 6 2 x 23 x 10 x 14.7 x 1729 15,000 6 3 78 x 10 in = 3 6 At 0.23 pounds per ft the weight = 22 x 10 pounds. This evaluation shows that the total container weight is independent of the storage pressure and also inde-pendent of the specific container radius selected. It is considered that standard wall piping would be the type of storage cenponent which could be most readily obtained in a timely manner for the system. Use of 36-inch O.D. standard wall piping (0.375-inch thick) was selected based on the following considera-tions: Use of a smaller diameter standard wall pipe would result in a higher storage pressure, whien has a higher potential for inadvertent system leakage. In addition, while the total volume of piping would decrease, the total length of piping would increase. Accordingly, the number of field welds wnich would be required would in-crease. Use of a larger diameter standard wall pipe is desirable in that the storage pressure and number of field welds would be reduced. Mcwever, the availability of piping decreases in the larger sizes, and the difficulty of performing field welds increases. Accordingly, while not optimized, use of 36-inch O.D. piping is considered a reasonable balance between availability, storage pressure, and ease of installation, 1741 170 e g

31. (continued) Pertinent parameters for a system which employs 36-inch standard wall piping are as fo110ws: Storace Pressure In accordance with the ASMI Code, Section III, sub-section ND, (Class 3 components), Paragraph ;D-3640: 2 x S x Et o = 2 v:

  • a D

0 Where: allowable pressure, psig P = a allowable stress S = 15,000 psig for typical carbon steel material = we.'d joint efficiency E = 1, with 100% radiography and arc-welded = joints 0.375 inch wall thickness t = = pipe utside diameter 36 inches D = = O 4 for pipe with D /t >6 y = 0 Accordingly: 2 x 15,000 x 1 x 0.375 P = a 36 - 2 x 4 x 0.375 340 psig = Storage Volume Frcm above: 6 23 x 10 x 14.7,3 .t V = S P 6 23~x 10 x 14.7 = 340 6 3 0.994 x 10 fg = 6 3 1.0 x 10 ft = e _.. __,, _.. g

31. (continued) Length of Pipe (36 - 2 x 0.375)2 Internal area = 975.91 in = 2 6.78 ft = Therefore. 6 #*3 1x'O Required length ^ = 6.78 ft' 147,000 feet = r 150,000 feet =

  • 7eight of Pipe r

From ANSI 336.10-1975, the weight of standard wall 36-inch pipe is 142.68 lbs/ft. Therefore: Pipe weight 150,000 x 142.68 = 6 21.4 x 10 lbs = Design Alternates Parameters for various desian alternates are defined in this section including (i) use of higher pressure piping, (2) use of a single large container, and (3) use of many standard gas stcrage bottles. (1) Use of Higher Pressure Pipinc The design pressure for 1.0-inch thick 36-inch piping is, in accordance with the previous sec-tion: 2 x 15,000 x 1.0 P = 36 - 2 x 4 x1 1,070 psig 1741 172 = g

n 31. (continued) The weight of such piping compared to standard wall piping would be propertional to the wall thickness and inversely proportional to the design pressure, i.e.: 6 1*0 '40 Weight 21.4 x 10 _ x = O.370 1,070 6 18.1 x 10 lbs = Accordingly, there is no significant weight savings associated with thicker walled piping. (2) Use of a Single Large Container Assume a vessel equivalent in volume to the existing containment vessel, i.e., 2 x 10D ft3, In accordance with Section 3.a., the storage pre r surr-for such a container would be: 6 23 x 10 x 14.7 p = 6 2 x 10 170 psig = With a radius of about 60 feet (720 inches), the wall thickness of such a container would be: N 170 x 720 t = 15,000 8.2 inches = Such a container would likely be significantly more costly and would take longer to construct than a system which employs standard wall piping. (3) Use of Standard Gas Bottles Standard high pressure gas storage bottles per ICC-2265 have che following parameters: Storage pressure: 2,500 psig Hydro pressure: 5,000 psig 1741 173 3 Capacity: 277 ft at STP 1

31. (continued) The required number of such bottles is therefore: 23 x 106 277 Or 83,000. The pipe and valve arrangement for a syst cause of the large number of bottles requirede em which Summary of Results a. Design Parameters of Basic system Pipe Size: 36-inch O.D. I thick walls) standard wall pipe (0.375-inch 1 ( Storage Pressure: 340 psig Storage Volume: 1 x 10 gg 6 3 Length of Pipe: 150,000 ft3 Neight of Pipe: 21.4 x 106 lbs b. pse of Higher Pressure Piping Pipe Size: 36-inch 0.D., 1.0-inch thich wall t i Storage Pressure: 1,070 psig Weight Savings: Negligible c. pse of a single Large Container i Container Volume: 6 3 2 x 10 ft Storage Pressure: 170 psig Required Wall Thickness (if carbon steel) : >3 inches d. Use of Standard Gas Bottles Number of bottles required:_ 83,000 Conclusiong )[k) )7k f Use of standard wall piping, l considered the most about reasonable approach.36-inch diameter, is e 1

.F 31. (continued) hie' din-Lvaluntion The shielding evaluation contains a term which is related 'y gecmetry to the total gammas per second r from Kr-85 disintegrations, S. a For 1 pCi/mi of Kr-85 and 2 x 10~ ft of containment volume, the total curies of Kr-85, C, is: -6 4 4 1 x 10 x 2 x 10" x 2.S32 x 10 C = 3 56.6 x 10 curies = With 3.7 x 10^O disintegrations per second, and 0.01 l's produced per disintegration: 3 10 56.6 x 10 x 3.7 x 10 x 0.01 S = 13 2.1 x 10 l's/sec = 1741 175 i

4 31. (centinued) Another common term in the shielding evaluation is D the dose received in R/hr as a result of a gamna fp,x of 1 gamma per square centimeter per second. _u For the 0.5 Mev gammas frem Kr-85, D equals 10-a The subsequent evaluation is based on the methods and physical parameters ccatained in ANS/SD-76/14, "A Handbook of Radiation Shielding Data," dated July, 1976. This is referred to as "Ref. 1" in the following evaluation. From Ref. 1, the dose for an infinitely long cylinder is: 2 D xS xR xB R V 0 F (n/2,b) D = 2 (a + Z) Where: 3 volumetric source, l's/cm -sec S = V cvlinder radius R = 0 buildup factor B = Sievert's integral (Ref. 1, Page 2-9) F(t/2,b) = distance from outer surface to receptor a = effective cylinder radius considering Z = self-shielding s R for gas in 36-inch diameter cine = 0 b pt = attenuation coefficient for shielding p = materials, cm-1 shielding material thickness, em t = 1741 176 g

31. (continued) (1) High Activity Piping with S x-Inch Concrete Shielding 5s shown in Figure S.4-;, the outer section of hign activity piping contains 3/21 of the total high activity piping volume (which con-sists of 20 t of the total volume). Therefore, the volume of these outer pipes: 8/21 x 0.2 x V = 3 0.076 V = S Where V. total storage volume = d 6 1 x 10 fg3@ 340 psig = Also, the fraction of activity removed from containment is: 1 [1 - e-V /V} = 1 Where V volume processed = i V containment volume l = Therefore, the activitv removed by the centermost building pipe sections, where v'1 is or 0.124 of the total process volume (0.2 - 0.076)b (23 x 100 ft 9 stp), is: 6 6 [1 - e- ( 0.124 x 23 x 10 /2 x 10 ) ] = 0.76 = When 20% of the total volume is processed: 6 6 [1 - e- ( 0. 2 x 2 3 x 10 /2 x 10 ) ] = 0.90 = Therefore, the outermost pipe sections contain (0.90 - 0.76) or 0.14 of the total activity. 1741 177 I

A 31. (continued) "'he volume of these outer cioes is or 2.'5'x 109 21. 0.076 x 1 x 106 5:3, 1 ._._... Therefore: 0.14 xS _ _ _. _ _... _ _.. _.. _ __... S = V 9 _. - -. 2.15 x 10 . 0.14 x 2.1 x 10 9 2.15 x 10 =-13.7 x 10' l's/cc-sec - a+Z 1.5 feet E = 0 a -= 42 2eet minimum a+Z 3.5 feet 107 cm = = 2 R0-R = 1.5 feet 45.7 cm = _ _ __ _.. 0 2 3 ....._.RO= ..x 0 F(n/2,b) t . _._The shielding consists of 0.375 inches of carben steel pipe plus 6 inches of concrete. . Iron-l i l....._...p ( 0.~ 5 M e V 1's) ' O.659 (Ref. 1, Page 5-10) - ~ ~ = t i t 0.375 x 2.54 _=. 0.953 = s Concrete: -~ p(0.5 Mov l's) 'O.202 (Ref. 1, Page 5-11) = 6 x 2.54 15.24 t = = 17A1 f70 l/4l l.g Q I

31. (continued) 1 l l3 I

i. i i

t I i i i i i I j i, i '---~b~- =~ 0 ~. 6 5 9 x 0. 9 5 3 + 0. 2 0 2 x 15. 2 4 i 3.71 = -2 F(r/2, 3171) =. 1.5 x 10 .(Ref. 1, Page 2-9) i _B ~ i i I i From Ref. 1, Page 5-22, B 7.3. = i l I i -Do se -- -- l i Using values determined above: x 13. 7 x 10 x 2.1 x 10 x 7.3 x 1.5 x 10-2 Dose = IC.-6 2 7 i i 2 x 10 t i i _4 I i =.- 14. 7 x 10 R/hr l l 3 j i i i i 1.5 E /hr from a single pipe ~ i i I l I There are seven rows of.oi.ces at the outer face of the building, the highest being approximately i - -3 0 f e e t elevation. Accordingly, the rotal dose ._1__.) ..... __._would be about equivalent to that from three rows l l t I i of pipes, or N4.5 ex/hr. l i This is'less than the dose for a radiation area o:: 5 m.r/hr and is acceptable. ... ( 2 ) ' Low Activity Piping with No Concrete Shielding l ~----{ ~- J-j- As shown in Figure 8.4-3, the outermost sections of the low activity piping I l .,!.._.{ 400,000 ft contain 40% of the total processed volume, or 3 This is the last gas processed. j J, _;.. ; __.j { q.. 4. The fraction of total activity contained in other l -*-l. pipe sections is thus : i t _2..._ . _i.j _. i _____..._..: 6 6)] i - (0. 2 x 23 x 10 /2 x 10 ..,i. __ _...;i =..[1 - e e i l i l i 0,9990 . = i i i t ._...l...a.. 1 I g 1741 179 .__.g

i r *. 31. (centinued) Accordingly, the low activity piping contains 0.1% of the total activity. -3 1 x 10 xS S = V V -3 13 1 x 10 x 2.1 x 10 = 400,000 x 2.832 x 10' 1.85 y's/cc-sec = The ratio of source strength from high and low activity sections is: 2

13. 7 x 10

= e 40 1.80 The results in the previous section show that with no concrete shielding, the dose would be increased by a f actor of 1/[3 x F (-/2,b)], or: 1 9.1 = -2 7.3 x 1,5 x 10 Accordingly, the dose from icw activity piping will be less than 9.1/740 x 100 1.2% of high activity piping. = s 0.012 x 4.5 = 0.05 mr/hr which is acceptable. = 174i i80 ...g

4 s' and Schedule Esticate. Page 77, Section S.4.3, cost 32. 25 to 35 conths Provide a detail breakdewn to justify why it will take this system. to design and cons: rue: l d engineer used standard industry esti=ating an Our architect d :osts presented. scheduling techniques to deter =ine the times an f experience and and schedule esti=ates are based on years o I"ne cos: and are considered adequate for ase by Metro-considered judgerient A = ore detailed esticate would require greater politan Edison. d delays design detail, which would impose additicnal, unwarrante i I I in solving the Krypten-85 probles. l See the answer to question 30 for additienal details. 1741 181 t i t I, I i ~ ~ ~~ ~ --. e+w - _p w. _ ww w .. ~

4'% a 33. Page 85, Section 3.5.3, Cos: and schedule Estimates. Provide a detail breakdewn to justify why it will take 20 to 30 cen:hs to design and ccnstruct this systes. Our architec: engineer used standard industry esti=ating and scheduling techniques to determine the times and costs presented. The cos: and schedule esticates are based on years of experience and considered judge =ent and are considered adequate for use by Metropolitan Edisen. A core detailed esticate would require greater design detail, which would impose additional, unwarranted delays in solving the Kryp:an-85 proble. See the answer to Question 30 for addi:icnal details. I741 182

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