ML19224D002
| ML19224D002 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/11/1979 |
| From: | Janecek R COMMONWEALTH EDISON CO. |
| To: | Oconnor P Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7907100449 | |
| Download: ML19224D002 (3) | |
Text
Commonwealth Edison one Frst Nr eno N:a Ch cago m rc's Address Recty 'o Post Ctf ce Box 767 Chicago. W.rcis 6C690 June 11, 1979 Mr. Paul W. O'Connor Operating Reactors - Branch 2 U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Dresden Station Unit 1 Chemical Cleaning Facility Design Basis NRC Docket No. 50-10
Dear Mr. O'Connor:
This letter is in response to previous NRC Staff requests to confirm the extent to which the Dresden Unit 1 Chemical Cleaning Facility complies with Regulatory Guide 1.143.
The present Chemical Cleaning Facility was designed to contain and process contaminated solvent and rinses from the Unit 1 Chemical Cleaning.
In December of 1975, when the design basis of the facility was being developed, there were no definitive regulatory guides for the design and construction of a chemical cleaning facility.
There were approximately 90 regulatory guides covering specific design criteria for nuclear stations.
Because of the potentially large inventory (3000 + 1000 curies) of radioisotopes which would be contained in the facility and the unknown consequences of an unexpected release, the design requirements and the design of the facility were made to conform to the intent of these regulatory guides (issued as of December, 1975).
By mutual agreement of the managements of Catalytic, Commonwealth Edison, and DOW Nuclear Services (then Dow Industrial Services), the hold tanks which would contain spent chemical cleaning solvent, would be enclosed in a seismically designed vault.
This vault would also be designed to withstand vind and missiles generated by a design basis tornado.
In addition, process areas within the facility would be surrounded by a seismically designed wall to prevent release of liquid radwaste in the event of a design basis earthquake.
Also, no penetrations would be located in the wall below the height sufficient to contain the liquid inventory in the building.
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Commonwealth Edison NRC Docket No. 50-10 Mr. Paul W.
O'Connor: June 11, 1979 In designing these portions of the facility designated as Seismic Category I, accelerations equated with a safe shutdown earthquake (SSE) were used.
NRC Regulatory Guide 1.60 was used to obtain the design response spectra.
The design basis tornado characteristics were found in NRC Regulatory Guide 1.76 (Region I).
The design of the Chemical Cleaning Facility meets the design requirements of Regulatory Guide 1.143 for Solid Radwaste Systems with one exception.
The Regulatory Guide, Position 3, requires that the foundation and adjacent walls of structures that house the solid radwaste system be designed to Operating Basis Earthquake (OBE) Seismic Criteria.
This requirement is to insure that any spillage which may occur will be contained in the structure.
The 200 and 300 area walls and foundations were designed to this requirement.
The 400 area (solidification system) foundation and walls were not designed to withstand an OBE because less than 200 gallons of unsolidified radwaste will be present in this area at any given time.
Any spillage which may occur will be of a significantly small quantity and is not considered to be of danger to the public.
For Additional Desicn, Construction and Testina Criteria, Regulatory Position 4, requires that testing provisions should be incorporated to enable periodic evaluation of the operability and required functional performance of active components within the radwaste system.
These design criteria did not exist at the time the design basis was being established and have not been incorporated.
For the Quality Assurance for Radwaste Manacement Systems, Regulatory Position 6 requires that the system designer (Catalytic) perform independent verification of all designs.
The only portion of the design which was independently verified is the seismic design of the structure (defined as " safety-related").
The re-mainder of the systems were designed as typical non-safety related systems.
The procurement of materials was done by CECO. per our standard practice for procuring non-safety related materials.
The installation of the Seismic Category I structures, as defined above, was performed by a contractor with a Ceco approved O.A.
Program and was installed as a " Safety Related" structure.
The quality status of the concrete, reinforcing steel and structural steel erection was verified by tests performed by an independent testing laboratory purchased by Ceco.
The installation of piping materials and electrical wiring was performed as non-safety related activities.
Non-destructive examination, such as penetrant examination and radiography,was performed by the independent testing laboratory on all process piping weld joints to determine acceptability.
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Commonwealth Edison NRC Docket No. 50-10 Mr. Paul W. O'Connor: June 11, 1979 In the areas of radiation monitoring and protection, the design of the facility meets the requirements of Title 10 of the Code of Federal Regulations.
Title 10 requires that nuclear fac?.lities containing sources of radiation be monitored for the re'. ease of radioactive materials, and that standards be established for the protection of personnel radiation.
" Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and the Releases of Radioactive Materials in Liquid and Gas,aous Effluents from Lightwater Cooled Nuclear Power Plants,' Revision 1, was used to provide guidance for monitoring of racioactive releases from the facility.
Regulatory Guide 8.8, "Information Relevant to Ensuring the Occupational Radiation Elpsoures at Nuclear Power Stations Will Be as Low as Reasor. ably Achievable ( ALARA), "
Revision 1, was uced to provide guidance on the requirements for radiation protection.
Please address any questions you may have concerning this matter to this office.
One (1) signed original and thirty-nine (39) copies of this letter are provided for your use.
Very truly yours, 6?
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- snce, Robert F. vanecek Nuclear Licensing Administrator Boiling Water Reactors
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