ML19317H452

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Requests Addl Info to Complete Review of 800410 Rept on Submerged Demineralized Sys by 800606.Related Correspondence
ML19317H452
Person / Time
Site: Crane 
Issue date: 05/16/1980
From: Jay Collins
Office of Nuclear Reactor Regulation
To: Arnold R
METROPOLITAN EDISON CO.
Shared Package
ML19317H451 List:
References
CON-NRC-TMI-80-089, CON-NRC-TMI-80-89, FOIA-80-349 NUDOCS 8006060351
Download: ML19317H452 (9)


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pa "'4, UNITED STATES REyaTED COIEsp0NDEXCU f,,

NUCLEAR REGULATORY COMM!sslON yi g

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May 16, 1980 HRC/TMI-80-89 Docket No.60-320 Hr. R. C. Arnold Senior Vice President Metropolitan Edison Ccmpany 100 Interpace Parkway Parsippany, New Jersey 07054

Dear Mr. Arnold:

Subject:

Submerged Demineralized System Technical Evaluation Report We have reviewed your report, subject as above, transmitted to us with your letter TLL-160 dated April 10, 1980, and find that we need additional information to enable us to complete our evaluation. is a list of questions for which we would.like to have your

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responses by June 6, 1980. To facilitate an early response to these questions, our on-site staff is prepared to meet with you or your designated representatives at your earliest convenience to discuss our comments in more detail.

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John T. Collins Deputy Program Director TMI Program Office

Enclosure:

As Stated See Distribution List p \\ \\;= l l 4 N

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R. C. Arnold Metropolitan Edison C.ompany

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M'r. G. K. Hovey J. B. Lieberman, Esquire Director. THI-2

.Berlock, Israel, Lieberman Metropolitan Edison Company 26 Broadway P. O. Box 480 New York, NY 10004 Middletown, PA 17057 George F. Trowbridge, Esquire Mr. J. J. Barton Shaw, Pittman, Pot.ts & Trowbridge Manager, Site Operations TMI-2 1800 M Street, N.W.

Metropolitan Edison Comoany Washington, DC 20036 P. O. Box 480 Middletown, PA 17057 Ms. Mary V. Souths.rd, Chairperson Citizens for a Safe Environment Mr.' R. W. Heward P. O. Box 405 Radiological Control Manager, TMI-2 Harrisburg, PA 17108 Metropolitan Edison Company P. O. Box 480 Or. Walter H. Jordan Middletown, PA 17057 881 W. Outer Drive Oak Ridge, TN 37830 Manager, Plant Engineerin9 Dr. Linda W. Little Metropolitan Edison Company 5000 Hermitage Drive

  • P. O. Box 480 Raleigh, NC 27612 Middletown, PA 17057 Karin W. Carter, Esquire Mr. R. F. Wilson 505 Execu'.ive House Director, Technical Functions P. O. Scx 2357 Metropolitan Edison Company Harrisburg, PA 17120 P.O. Box 480 Middletown, PA 17057 Honorable !! ark Cohen 512 E-3 Main Capital Building i

Mr. L. W. Harding Harrisburg, PA 17120 Supervisor of Licensing Metropolitan Edison Company Ellyn Weiss, Esquire P. O. Box 480 Sheldon, Harmon, Roisman & Weiss ing o 20bd6 Licehsing Manager Mr. Steven C. Sholly GPU Service Corporation 304 S. Market Street 100 Interpace Parkway Mechanicsburg, PA 17055 Parsippany, NJ 07054 Mr. Thomas Gerusky Mr. I. R. Finfrock, Jr.

Bureau of Radiation Protection Jersey Central Power & Light Company P. O. Box 2063 Madison Avenue at Punch Bowl Road Harrisbur', PA 17120 g

Morristown, NJ 07950 Mr. Marvin I. Lewis Mr. R. W. Conrad 6504 Bradford Terrace Pennsylvania Electric Company Philadelphia, PA 19149 1007 Broad Street

' Johnstown, PA 15907 Ms. Jane Lee R. D. 3, Box 3521 Etters, PA 17319

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nr. R. C. Arnold lietropoli, tan Edison Company Walter W. Cohen, Consumer Advocate Ms. Kathy McCaughin Uepartment of Justice Three Mile Island Alert, Inc.

Strawberry Square, 14th Floor 23 South 21st Street Harrisburg, PA 17127 Harrisburg, PA 17104 Robert L. Knupp, Esquire Ms. Marjorie H. Aamodt Assistant Solicitor R. D. iS Knupp and Andrews Coatesville, PA 19320 P. O. Box P 407 N. Front Street Ms. Karen Sheldca Harrisburg, PA 17108 Sheldon, Harmon', Roisman & Weiss 1725 I Street, N.W., Suite 506 John E. Minnich, Chairperson

!!ashington, DC 20006 Cauphin Co. Board of Commissioners Cauphin County Courthouse Earl B. Hof fman Front and Market Streets Dauphin County Cor.raissioner Harrisburg, PA 17101 Dauphin County Courthouse Front and Market Street Robert Q. Pollard Harrisburg, PA 17101 Chesapeak Energy Alliance 609 Montpelier Street Government Publications Section Bal tim' ore, MD 21218 State of Library of Pennsylvania Box 1601 Education Building Chauncey Kepford Harrisburg, PA 17127 :

Judith H. Johnsrud Environmental Coalition on Nuclear Pow 4r Dr. Edward O. Swartz 433 Orlando Avenue Board of Supervisors State College, PA 16801 Londonderry Township RFD fl Geyers Church Road Ms. Frieda Ber'ryhill, Chairperson Middletown, PA 17057 Coalition for Nuclear Power Plant Postponement U. S. Environmental Protection Agency 2610 Grendon Drive Region III Office Wilmington, DE 19808 ATTN:

EIS COORDINATOR Curtis Building (Sixth Floor)

Holly S. Keck 6th and Walnut Streets Anti-Nuclear Group Representing,Y,ork Philadelphia, PA 19106 245 W. Philadelphia Street York, PA 17404 Cauphin County Office Emergency Preparedness John Levin, Esquire Court House, Room 7 Pennsylvania Public Utilities Comission front and Market Streets P. O. Box 3265 Harrisburg PA 17101 Harrisburg, PA 17120 Department of Enviornmental Resources Joedon D. Cunningham, Esquire ATTH:

Director, Office of Fox, Farr and Cunningham Radiological Health

.2320 H. Second Street P. O. Box 2063 Harrisburg, PA 17110 Harrisburg, PA 175 W

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Mr. R. C. Arnold Metropolitan Edison Company G' overnor's Office of State.

Planning and Development ATTN: Coordinator, Pennsylvania Clearinghouse P. O. Box 1323 Harr,'sburg, PA 17120 Mrs. Rhoda D. Carr 1402 Marene Drive Harrisburg, PA 17109 Mr. Richard Roberts The Patriot 812 !!arket Street Harrisburg, PA 17105 Mr. Robert 8. Borsum Sabcock a Wilcox Nuclear Power Ger,eration Division Sui te, 420, 7735 Old Georgetown Road Bethesda, MD 20014 Ivan W. f aith, Esquire Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission' Washington, DC 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, OC 20555 Atomic Safety and Licensing Appeal Panel U. S. Nuclear Regulatory Commission

' Washington, DC 20555 Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D,C 20555 S

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ENCLOSURE I CCMMENTS ON SUBMERGE 0 DEMINERALIZER SYSTEM TECHNICAL EVALUATION REPORT

GENERAL COMMENT

S 1.

Provide (1) a complete set of Piping and Instrument Diagrams (P&ID),

(2) general arrangement drawings, (3) zeolite, cation, and filter vessel internal drawings, and (4) the system description document of the latest revision for the 505.

2.

Provide a complete process flow diagram indicating (a) expected radioactivity concentration (uCi/ml) in each process stream including the final processed water for each radionuclide present, and (b) expected concentrations (ppm or ppb) of nonradioactive chemicals in each process stream.

Include test results, references, and any supporting documents to support and substantiate the decontamination factors you assumed.

3.

Provide expected radioactivity loading (Ci) and throughput (gallons) in each pre-filter, final filter, zeolite bed, cation bed, and polishing demineralizer.

4.

Provide expected solid loading capacity for pre and final filters and estimate number of spent filter vessels to be generated as a result of SDS operation.

5.

Provide expected number of spent resin vessels (zeolite, cation, and pool purification mixed-bed) to be generated during operation of the SDS.

6.

Describe process flow and method for processing the reactor coolant through the SDS and/or EPICOR II.

d 7.

Describe the design and operational features of SDS polishing demineralizer.

8.

Provide the maximum expected tritium concentration in the TMI-2 fuel pool water with anticipated routine leakage (coupling and decoupling operations of filter and resin vessels) as a result of SDS operation.

9.

Provide expected fuel pool water temperature, water volume, evaporation rate, and area ventilation flow rate, and resulting airborne tritium concentration in the TMI-l and TMI-2 Fuel Handling Areas during operation of the SDS.

10.

Describe the provisions provided for the removal and disposal of spent resin fron. the SDS polishing unit demineralizer.

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SPECIFIC COMMENTS 1.

Page 1-1, paragraph 1.1 State if specific process features include processing of rinse water through the 505.

If so, estimate the volume and radioactivity concentration of rinse water.

2.

Page 1-2, Alternative I Based on past experience, project the reactor building water level for next two years and list the critical instruments that may be affected by the water level you projected.

3.

Page 1-2, Alternative I You state that the radiation dose at the surface of the sump water measures approximately 120 R/hr. State expected radiation dose rate at the same elevation after removing all waste water in the reactor building.

4.

Page 1-3, Alternative II You state that the construction of a waste storage facility would exceed two years. Describe the waste storage facility considered and state estimated radiation doses from the facility.

5.

Page 1-3, Alternative II Include in your evaluation a solidification system that would utilize a large liner for direct solidification of containment sump waste water.

6.

Page 1-7, paragraph 1.4.2 d

What is the " desired bed loading" for the first zeolite bed.

Discuss the manner in which the loading'will be determined during operation. Also discuss loading in terms of integrated dose rate limitations and the potential for gas generation while in store.

7.

Page 1-7, paragraph 1.4.2 Is it the intent to store the organic cation bed underwater in the storage rack? If not, how will they be disposed of?

8.

Page 'l-8, first paragraph You state that cation resin will be limited to less than 75 Ci of strontium based on zeolite bed effluent monitoring.

State strontium analysis capability at the TMI site to sustain SDS process without delay.

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9.

Page 1-8, second p~aragraph Describe design and operational features of beta monitors in detail.

Are they designed for cesium or strontium breakthrough?

10. Page 1-8, line 2 At a loading of 75 curies of strontium on the cation bed, what is the expected cesium loading? What is the bases for limiting integrated dose rate to 100 rads?,
11. Page 2-1. line 10 Provide estimates of the expected occupational exposures from the processing of sump and RCS water, and handling of all generated solid waste, including filters.

Provide the bases for your estimates.

12. Page 2-1, line 2 Identify those components which will require shielding, in addition to those in the fuel pool, to reduce dose rates to less than one (1) mR/hr. Also include components in the SDS off-gas system.
13. Page 2-2, paragraph 2.3 l

l Provide the basis for the 450 gallons water being released to the pool and for the 233,000 gallons of additional contaminated water.

14. Page 2-2, last paragraph You state "It is possible that workers could be contaminated, however, prompt emergency deconts.nination procedures would prevent major radiation exposures".

Elaoorate this statement and describe the location and the method to be used for prompt emergency decontamination procedures. Provide the basis for the 11 R/hr maximum exposure

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rate assumed.

15. Page 2-4, paragraph 2.6 Discuss ultimate disposition of generated solid radwaste in greater detail. Describe storage capability for spent liners, spent resin processing, cask availability for shipment, and acceptability of the processed waste at a low level waste burial facility.
16. Page 3-5, paragraph 3.4 You state that the results of recent experimental work with simulated and actual water samples from TMI-2 were used to support the selection of specific ion exchanger materials for the SDS.

Provide a copy of such test results to the HRC for review.

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17.

Page 3-5, paragraph 3.4

.You state that only 200 bed volumes (approximately 2000 cubic. feet" or 15,000 gallons) of waste water are anticipated to be processed before the first zeolite bed is removed and replaced.

This will require more than 60 zeolite bed replacement (excluding the subsequent zeolite beds, cation beds, and filters) to process one million gallons of waste water.through the SDS. Justify the storage capacity provided for only 40 spent vessels in the fuel pool.

18. Page 4-6, line 6 Provide the flow capacity of the pool secondary containment demineralizers.
19. Page 5-2, line 1 Provide the administrative surface dose rate limit for change out of the SDS filters.
20. Page 5-6, line 6 Describe how the shipping cask a'nd its' contained liner will be

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drained prior to movement out of the pool.

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21. Page 5-2, line 1 Describe how spent SDS filters will be changed out and packaged for ultimate disposition.

22.

Page 5-1, paragraph 5.1 The SDS feed tanks can be considered as one feed tank with a 4

capacity of 60,000 gallons since there are no valves between these feed tanks and two nonitor tanks which receive processed waste water have a capacity of 19,100 gallons each.

Describe the criteria for determining the batch volume without risking radioactivity contamination of already processed water in the monitor tanks. The in-line monitors may not provide the sensitivity required to detect desired radioactivity breakthrough due to the radioactivity plateout and background radiation buildup.

23.

Page 5-1, paragraph 5.1.1 Provide estimated contact dose on spent filter, zeolite, and cation vessel casks.

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24. Page 5-3, paragraph 5.1.4 You have provided an in-line monitor in a ccamon recirculation. lin'e from all vessel containment boxes to the leakage containment ion exchangers. Describe leakage detection method to identify the source of leakage from each vessel containment box.

Describe also how you would distinguish accidental leakage from the leakages resulting from routine connections and disconnections of vessels.

25. Page 5-4, paragraph 5.2 Describe leakage detection method provided within Hi-Rad Filter clove Box, Hi-Rad Feed Sample Box, Intermediate Level Sampling Glove Box, and Beta Monitor Manifold.

Describe (1) type of analysis

  • o be performed on Hi-Rad samp'es, and (2) capability of such m alyses on the TMI site.
26. Page 5-6, paragraph 5.5 You state that the capability to solidify the spent resin vessels generated by the operation of the SDS has been developed.

Describe the capability and process involved in detail.

27. Page 6-6, line 15 Provide an estimate of dissolved Kr-85 concentration and include it as a part of the gaseous source term.
28. Page /-2, line 12 Wouldn't the compartment cleanup and monitoring system for the pool water indicate a leakage contamination problem long before area radiation monitors in SDS area would detect such leakage? What level are these area monitor alarms set? Provide type, number, location, and set point for all area radiation monitors.
29. Page 7-1, paragraph 7.1 and 7.2 State if the reactor building water pump and SDS feed pump are provided with automatic trip upon detection of a preset high radiation level by in-line radiation monitor (RE527-13), fuel pool area monitors, and/or radiation monitors in the filter contair~nt boxes.
30. Page 7-1, paragraph 7.1 and 7.2 Provide estimated annual dose for any individual in an unrestricted area and population dose resulting from hypothetical accidents considered.

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