ML19329B054

Forwards Detailed Comments from Acceptance Review of FSAR by Site Analysis,Hydrologic Engineering,Accident Analysis & Radiological Assessment Branches.Site Safety Branch Believes Rept Too Incomplete for Acceptance

ML19329B054
Person / Time
Site:	Davis Besse
Issue date:	01/04/1973
From:	Harold Denton US ATOMIC ENERGY COMMISSION (AEC)
To:	Deyoung R US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8001300652
Download: ML19329B054 (18)

Text

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R. C. DeYoung, Assistant Director for PWR's, L MVIS-BESSE FSAR ACCEFrAMN EIVIEW i

i FLANY NAME: Davis-Besse LICENSING STAGE: FSAR Acceptance Xaview DOCIET NO: 50-346 RESPONSIBLE BEANCH: PWR f4 FROJECT MANAGER:

H. Faulkner i

DMI REQUEST RECEIVED: December 15, 1972 REQUESTED COMPLETION MTE: Jar-ary 3,1973 DESCRIPTION OF RESPOfGE: Sito Safety recosamendation for not docketing i

REVIEd STATUS: Sits Safety - Commplete to this stage With respect to its areas of concern, Site Safety does not consider the report to be sufficiently complete for acceptance at this time. The principal inadequacies with respect to completeness were found in the areas of engineered safety feature (dese mitigation) design and hydro-logic engineering. The enclosure provides our detailed connents.

Although our commsents in some instances are provided in accordance with l

Revision 1 of the SAR Guide, we have made our overa11' judgment in the light of the February edition. Where differences occur, the applicant may be allowed additional time to complete his submittal, but, neverthe-less, the information indicated will eventually be necessary to complete our evaluation.

Om i ay IL It Deuten Harold R. Denton, Assistant Director for Site Safety Directorate of Licensing

Enclosure:

As stated Distribution:

Docket file i

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Forms AEC-Hs (Rev. 9-53) AECM 0240

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3. Grimes A. Kenneke H. Faulkner M. Parsont i

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-^-s DAVIS-EESSE 50-346 MINI-FSVIEW Secticns 2.1 and 2.2 are satisfactory, t

Section 15.0 Item 23 Fuel Handling Accident Analysis dces act I

- conform to the AEC staff model of assuming the failure of a ec=plete fuel bundle.

(The applicant assumed the failure of 56 cut of 2CS

. fuel reds.)

l Astericked items on 'following pages refer to October issue of Standard Format.

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/s,,s SITE ANALYSIS BRANCH DAVIS-BESSE COMMENTS ON FSAR Section 2.3

- Meteorology The meteorology section of the<FSAR is reasonably complete and is considered acceptable.

However, some additional information should be provided by the applicant and some statements in the FSAR clarified.

The applicant should be requested to provide the

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following information:

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A table of annual average atmospheric dispersion (X/Q) estimates for 16 radial sectors to a distance of 50 miles from the plant.

2.

Evidence that the accuracy of the meteorological measurement equipment to be used in t,h e operational onsite measurement program, especially with respect to the dewpoint measurements, meet the accuracy criteria recommended in Safety

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Guide 23.

3.

A copy of a study of the potential effects of the cooling towers on the environment that is mentioned.in section 2.3.2.3 of tae FSAR.

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i and humidity data

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A full year of onsite temperature with a j oint data recovery rate of at least 90 as such dat. become available.

percent as soon The applicant, in section 2.3.1.2.8, firs,t 2-34 of t h'e FSAR, states that paragraph, page high air pollution potential (atmospheric stagnation) conditions occur 20 to 30 percent of the' time at the plant site.

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by the staff that these values must be in error.

The applicant should be asked to verify the

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statement.

Finally, section 2.3.1 of the

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titled FSAR-Regional Meteorology - should be

" Regional Climatology."

"hese questions can be The staff feels that t

resolved at an early meeting with the applicant or through a response by the applicant to one

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round of questions from the staff.

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ENGINEERING MINI-REVIEW HYuROLOGIC DAVIS-BESSE NUCLEAR POWER STATION FSAR SAR Guide (Rev. 1)

Comment Section No. & Title 2.4.1 Hydrologic Description Describe site drainage facilities, including che roofs of safety-related structures.

2.4.2 Floods 2.4.2.1.

Flooding History De s c rib e the meteorology surge and waves which occurred in the region in the fall of

1972, 2.4.2.2 Flood Design Considerations Provide the bases for site drainage, inc.luding the roofs o f s af e ty-related b uildings,

against heavy rainfall, and the intake canal side slopes, N

intake, and both sides of the end structure to resist wave action.

Provide a descriptier of the canal and its terminal structures (profiles and cross sections).

2.4.3 Probable Maximum Flood (PMF) on Streams & Rivers Provide additional bases for concluding a PMF on Toussaint River does not constitute a flood threat to the plant.

Provide p rob ab le maximum rain-f all es timates for site drainage and an analysis whict demonstrates overflow (in-cluding roof drains of safety-related buildings) will not constitute a flood threat.

.2.4.5 P rob ab le Maximum Surge and Seiche Flooding Compare the postulated piobabi.

maximum meteorological event with the 1972 seiche-causing storm to determine whether the p rob ab le maximum event is adequate as an upper limit avc Verify the prob able maximum surge model by reconstituting %

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Comment SAR Guide (Rev. 1)

Section No. & Title the 1972 surge.

Provide th e b as es for the wave escinates

.provided, including-the components attributable to wave action refracted and reflected from and through

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offshore islands.

Provide estimates of wave action on the lakeside of the intake canal terminal structure and along the intake canal.

Discuss the potential for wave-i induced resonance in the intake canal.

(Cross referencc sections 2.4.2.2 and 2.4.8).

2.4.11 Low-Water Cons id e r a tions Demonstrate the heat dissipation and inventory capability o f the intake s

canal under the postulated low water surge conditions discussed in section 2.4.11.6.

4 Discuss hydraulic short-circuiting potential under thi condition, and under any other.

postulated condition requiting the use of the canal for total or partial recirculation.

Describe the intake and dis-charge facilities along the canal for this mode of operation.

Compare postulatec environmental conditions with the guidelines suggested i r.

Safety Guide 27, or appro-priately cross reference o th e r sections of the FSAR containir such rcterial.

2.4.12 Environmental Acceptance of Effluents De s cr ib e the range of anticipated dilution for normal and inadvertant releasc to the lake and local public water supplies, to adj acen t

[ ground water users.by direct

'sub surf ace movement and by

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Comment SAR Guide (Rev. 1)

Section No. & Title lake recharge of adj acent aquifers.

4 Provide estimates of surficial 2.4.13 Groundwater soil permeabilities in plant site area, and along lake front near well users.

2.4.14 Technical Specifications _&

Emergency Operation Because th e cooling tower and Re q uire me n ts portions of the water supply sys tem may not be capable of withstanding extremely adverse hydrologically-related events, provide tech specs which assure a cold shutdown in advance of the occurrence of events which could cause the loss of safety systems, or portions thereof, required for operation.

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e ACCIDEm' ANALYSIS BRANCH REVIEW 0F DAVIS-BESSE FSAR, CONTAIMMENT SPRAY SYSTEM In Chapter 15,- Section 15.6.6.3 and 15.4.6.4 of a DRF of 1.7 for 0-2 hours, and 3.6 for 0-30 days, is claimed for the iodine cleanup effect of the boric However, this paragraph in 15.4.6.4 is the only place acid spray system.

where the iodine removal function of the containment spray system is referred to. The following information is missing in its entirety:

6.2.3 Containment Air Purification and Cleanup Systems:

Description of. the iodine removal function of the Containment Spray System 6.2.3.1 Design Basis (for iodine removal function) 6.2.3.2 3ystem Design (as affected by iodine removal function) i 6.2.3.3 Design Evaluation Evaluation of iodine removal function of the contaminent In 'this section, sepcific attention should spray system.

be given to the evaluation of the effects of spray solution a

chemistry, drop size spectrum, drop coalescence, steam condensation, drop saturation, iodine partition ccefficient, containment coverage, unsprayed volumes, wall effects, and mixing in the sump.

Sections 6.2.3.4, 6.2.3.5 and 6.2.3.6 may be covered by reference to previous sections supplied in the description of the heat removal function of the containment spray system.

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a In chapter 15, the fo iowing sections are missing in,tachr entirety:

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15.1.X.2 '(1) Estimated course of events, as related to actuation of the contaidment clean-up function of the spray system.

'(2) Mathematical model employed to perform the analysis of iodine removal by spray, and the resulting dose reduction factor.

(3)

Identification of any ccmputer programs used in the analysis.

(4b) Fission product concentrations in the contair. ment atmosphere and the sump solu $ tion (as a function of time) used in the I

spray icdine removal analyais, particularly tneir effect on the.fcdine partition coefficient.

(7) Justification of assumptions used, with reference to experimenta',

data.

(8) System interdependency, particularly the interdependency of containment spray and filtration systems on the dose reducticr.

factor claimed for each system.

(9) Results of analysis of iodine removal by sprays, and the margin of protection provided.

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ACCIDE?tT ANALYSIS 3 RANCH OAVIS-BESSE COMMENTS ON FSAR Section 9.4.1

'Concerning the charcoal filter for the control room emergency ventilation system, provide the following:

filter flow and residence time of filter amount and type of charcoal in filter description of charcoal'impregnants if any flow rates during normal and er.ergency cor.ditions of ventilation system discussion of strategies used to operate the ventilation system under all conce?vaMe emergency conditions.

• Sections 15.3.1 and.2 These sections deal with small activity leaks.

Provide discussions of the methods of detection and the time required to evaluate the occurrence and isolate,the system or take other remedial action (see Standard Format 15.1. X.2-(l) )

Section 15.4.2.2.2 (1.b.)

Evaluate a case where the steam generacor tube rupture results in a leak equal to the primary feed water make-up capability. How will this event be detected and are the consequences worse than the case presented?

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-s Table 15.4.6 - 3 This table summarizes operator exposure during a MHA. -

Please The assumptions used in arriving at these exposures are not given.

provide the following information concerning control room protection:

1.

Provide an analyses of the thyroid, beta skin, and whole body gadma doses received by control room operators during accident situations. The dose contribution frcm each separate source of radioactivity should be tabulated. When evaluating the effective-ness of the control room protection features, all types of accidents should be considered; however, only the limiting accidents need be analyzed in detail. As a minimum, calculate the doses received by the control roca operator frca a loss-of-ccolant accident, a fuel handling accident and a waste gas decay tank accident. Clearly describe or reference the method used to calculate the doses.

Provide a complete list of assumptions and input data, including:

(a) The source terms used for each peint of release. Consider all potential sources of radioactivity including contain-ment leakage, exfiltration if any, vent releases, penetration leakage and activity which may be transferred direccly to the control room from the radwaste and turbine buildings and frcm other portions of the control building.

(See item c.)

(b) The distances between the points of radioactivity release for each design basis accident and the air intake to the control room.

(c) An evaluation of the potential for radioactive material, noxicus gases, or steam to be transferred directly into the control rocm from adjacent areas and buildings. inis should include a description of all pote ~ial paths for

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, transport such as the duct work, corridors, dcorways, elevator shaft's, etc. -

(d) The expected dilution factors between the expected release points and the control room air intake (or other appropriate opening). Assumptions as to wind speed and exposure frequency made during the course of the accident should be clearly stated.

Provide technical references and/orexperimental data to justify the factors used in your analysis.

2.

Identify toxic material, such as chlorine, that may be stored on or in the vicinity of the site, which, assuming a container rupture, may interfere with control room operation.

List the distances between the location of any such material and the air intake to the control room.

Provide an analysis of the severity of such accidents, and discuss the steps to mitigate their consequences. The description of the analysis should clearly list all' assumptions.

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ACCIDENT A.NALYSIS BRANCH DAVIS SESSE COMMENTS ON FSAR I.

Add to Section 9.4.1 Supply the same information for the c.ntrol rocm filtration as was supplied for the containment air purification and cleanup systems of r/

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Section 6.2.3.

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• II. As required by 6.2.3.2 of the SAR guide supply (1) preliminary piping and instrumentation diagrams of~ the ventilation and other clean up systems.

(2) Where building recirculation systems are provided the system description should include a discussion of the mode (s) of operation and mixing behavior. Layout drawings of system equipment and air flow guidance ducts should be provided (FSAR). Provide the expectec initial and final exhaust flow rates and the rate of change between initial and final flow rates; the recirculation rate; and the mixing l

volume.

III. The filtration systems should include demisters, heaters and HE?A filters downstream of the adsorption unit.

• IV. List by type (epoxy, pher+elic, xinc, etc.) and manufacturer's designation all known paints used in the contair. ment.

In addition list the dry density and surface area covered by each paint. List the total. surface

-area and estimated volume covered by unkncwn paints.

Explicitly state the curing procedures applied or to be applied for each paint. A

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quality assurance program for paint applications should be detailed in Chapter 17.

• V Insufficient details and design criteria of the reactor building sump.

and its intake screens are given.

Construction and layout' details of the containment sump should include:

(a) the degree to which the concept has been, or wi'l be, proven sufficiently by experience, tests under simulated accident conditions, or conservative extrapolations frcm peesent knowledge; (b) how the systam will function during the entire period required to accomplish its intended purpose (e.g., include consideration of component reliability, system interdependency, redundancy and separation of components or portions of syscem);

and (c) provisions made for initial and periodic testing and surveillance.

An analysis of the containment sump should be given which describes the flow path and restrictions (including sizes) which a particle wculd follow in circulating the different systems which must use the sump as a source. An analysis describing the eventual fate of painc chips or other debris which may enter the sump should be presented.

VI.

Boric acid sprays are used in the plant. The ability of the plant to

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raise the pH of the spray solution to at least 7 within four hours of the onset of the LCCA in order to preclude stress corrosion cracking is not given.

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VII. As required by Section 6.2.3.4 of the SAR Guide-Provide information concerning the program of testing and inspectio*n applicable to preopeaational testing and in-service surveillance to assure a continued state of readiness to perform for those ventilation and cleanup systems required to reduce he radiological consequences of an accident.

Results of tests performed and a detailed, updated program should be provided (FSA?.).

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RADIOLOGICAL ASS 2SSMEST BR/'J:CH DAVIS-3 ESSE CC.V.ENTS ON FSAR d

Chapter 11 is.cpprc::imately 807. completed from the standpoint of RA3--the most notable-deficiencies being in omission of the radweste system design and perfor=cace tests secticas, and that the environmental radiological s:=pling progra= should bc =uch further developed at this stage of licensing (and there should be so=e discussion of both preoperational. and opera:ional aspec:s of the progrc=).

Chapter 11 The System Designs, Performance Tests, and pertinent experience for Geseous and Liquid ledwaste Systc=s are not adecuately presented. Applicane. is referred to " Standard Zor=st" sections 11.2.3, 11.2.5, 11.3.3, and 11.3.5.

Sec: ion 11.2.8

1) Fresent c =:p illustrating the locacica of Ohio Fishing District I with respect to discharge canal.

2) Give bcsis for the statement that a dilution factor of 5000 is conser-vative.

3) The tex: indicates that at G.o miles the. dilution factor is 4070--justify the value of 5000 at 5 miles.

i Section 11.6.3

.Prepara a sui:able map showin3 the site boundcry and the location of all sc=pling poin:s and indicate either in a : ble or on the map the :ypes of sc=ples to be taken at each poin: es well as the sa=pling frequency. Justify

.the selection of sa=pling locations.

The necessary sensitivity for I detection in = ilk should be at least lpCi/1.

Describe' :he =ethods by which pulces of radiocceivity, with half lives short in co=parison to the sa:pling free,uency, will be detected in the environ =ent--

for exa=ple, = ilk s==ples and I-131.

Indicate che follouing information on a =cp of suitchle scale (the =cp shouin; the sa=pling locations would be cceeptable).

1) The location of the ne:res:

residencas (uichin 3 miles) outside the sita beundary, 2) the location of the nearest cows, 3) the _ location of the nearcst possible pasture.

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n Appendix 11 A The models for the calculation of dose to biota are not presented.

Chapter 12 The information provided in Chapter 12 is approxt=ately 907. co=plete. The follouing ite=s which are numbered in accord nce with the sections of the FSAR to which they apply should be addressed so that RA3 can complete their review.

12.1.4 Describe the records of in-plant area radiation levels that will bc =aintained and the length of ti=c they vill be retained.

12.1.6 Provide esci=a:es of typicci yearly c:::crnal dos'e rates to plant personnel for nor=al oper:: ion. These estimates can be obtained by supplying the length of ti=c. (brs/wk) personnel are expec:ed to spend in the areas listed in Table 12-5A.

12.2.4 Describe the records of in-plant airborne radioactivity levels : hat will bc main:sined and the length of ti=c for which they will be retained.

12.2.6 Provide esti=stes of typical y'carly inhalation dose rates to plant personnel for nor=cl operation.

12.3.1 Provide a description of the health physics program organization and the duties of individuals within the organization.

12.3.2.1 Indicate the personnel responsible for issuing rcdiction work per=ics cnd the information necessary for their issuence.

Based on the =c:erial presented in the FSAR, although lacking in certain respects, we feel tha: the presentation is cceeptable. This acceptance is based on pro =pt submittal of the infornation necessary to co=plete these sections, i

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