ML19338F506

Notifies That Safety Evaluation of Submerged Demineralizer Sys Per 10CFR50.59 Will Be Submitted on 801201,in Response to NRC .All Requested Safety Evaluation Elements Were Previously Addressed in 800410 Submittal

ML19338F506
Person / Time
Site:	Crane
Issue date:	10/13/1980
From:	Hovey G METROPOLITAN EDISON CO.
To:	Jay Collins Office of Nuclear Reactor Regulation
References
TLL-478, NUDOCS 8010200438
Download: ML19338F506 (4)

Text

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Metropolion Edisms Company ff g')

Post Office Bc 480 Micdletown, Pennsylvania 17057

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Writer's Direct Dial Number Oc tober 13, 1980 TLL 478 TMI Program Office Atta:

Mr. J. T. Collins e/o Three Mile Island Nuclear Station Middletown, PA 17057

Dear Sir:

Three Mile Island Nuclear Station. Unit 2 (TMI-2)

Operating License No DPh-73 Docket Jo.56-320 Submerged Demineralizer System This letter is forwarded in response to your letter dated September 13, 1980.

In that letter you state that the NRC staf f considers our proposed method to decontaminate the reactor building sump water, the Submerged Pemineralizer

. System (SDS), would be a f acility change as described in 10CFR50.59 which may require prior NRC approval.' Furthermore, you state that part of your review of the SDS 'will require submission by Met-Ed of a comprehensive written safety evaluation to determine if such a change would involve an unreviewed safety question and/or a change in the Technical Specifications for the facility, and hence a license m:endment.

We recognize the requirement to perform a safety evaluation in accordance with 10CFR50 59 and intend to submit the document to you by December 1, 1980.

However, we wish to point out that the document previously submitted (the SOS Technical Evaluation Report) and in your hands for many months contains t e necessary information to facilitate your review of our proposal.

On April 10, 1980, via letter TLL 160, we transmitted our Technical Evaluation Report (TER) for the Submerged Demineralizer System. The TER provides a dasciption of the proposed system and the results of our analysis of the operation of the system. Considered in our analysis are the following concerns:

1.

A summary of our treatment plan for RCS water and containment sump water including the altern'ative methods considered.

2.

A process description of the selected method for water decontamination.

3.

The design basis for the system.

4.

A description of the system and the system layout and placement within the TM1-2 f acility.

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adiation protection analysis including:

a.

ALARA design considerations.

.b.

' ALARA considerations during operation.

Facility design features -for radiation protection including shielding c.

design, ventilation.dasign, and radiation monitoring instrumentation.

d.

Dose ' Assessment for on-site and off-site radiological exposures.

. 6.

Rypothetical accident analysis.

~ In our April' 10, 1980 letter.we state:

- We talieve the' SDS represents an optimum system for decontamination of 'the containment sump water and reactor coolant system water. Your early approval for use of this system is requected."

The issuance of a TER to 'the NRC was intended as 'the vehicle for communication to NRC of technical information to support NRC's review and approval of proposed L

THI-2 recovery systems and f acilities.

Specifically, your letter promulgates IE Circular 80-18:

10CFR50.59 SAFETY EVALUATIONS FOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS. This circular was issued subsequent to our April 10 submittal and it provides guidelines concerning criteria that should be reviewed prior to the modification of radio-4

' active waste systems. Some of these criteria are:

1.

System modifications should be evaluated against.the seismic, quality group and quality assurance criteria in Regulatory Guide 1.143.

Design provisions?for controlling releases of radioactive liquids, as presented in Regulatory Guide 1.143, should also be evaluated.

2.

Radiological controls should be evaluated against the criteria in Regulatory Guide 1.21 and Standard Review Plan 11 5, " Process and Ef fluent Radiological. Monitoring and Sampling Systems".

3.

Systems involving ~ potentially explosive mixtures should be evaluated against the^ criteria in Standard Review Plan Section 11.3, " Gaseous Waste Management System", subsection II, item 6.

System design and. operation should be evaluated to assure that the 4..

radiological" consequences of l unexpected and uncontrolled ' releases of radioactivity :that -is ~ stored or transferred in a waste system are a small fraction of the 10CFR100 guidelines; i.e., less than 0.5 rem whole body dose,- 1.5 -ren thyroid from gaseous releases, and less than the-radionuclide concentrations of 10CFR20, Appendix.B, Table II, Colunn,2 from supplies. :(See LStandard Review Plan Sections 15.7.1,

15. 7 2, - and 15. 7. 3 f o r mo re - de tails.)

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ql - I The[above crit'eria have[beeniaddressed kin our TER, with the : exception o'f' iM DiteaM3.. Potentially explosivo mixtures _have not been addressed in our sub--

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" mittel becassek to;the best ofj our knowl' edge, l operation of f the SDS does not

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iinvolve the' generation 6riuseiof-potentially explosive mixtures.

As indicated [in ourf SDS TER, 'sectionj4.3E1,ithe regulatory guidance provided in..

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Regulatory Guide bl43 has been _followuf for Lthe.designiof Ithe SDS. Thec iguidance(followenrelates' to ' seismic; qualitiy group and; quality assurance The! control"of' relea' esi'of ;radioactivefliquids is a

positive one;

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s f :n( SDS Llihuid (ef fluentswill ~be directly released to 'the environment.

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The guidance provided(in[ Regulatory; Gdide 1.21

.s been -followed in the d'esign Lof the!SDS..oIn. fact.there are no planned.11.. id. releases from che: SDS

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gaseous;effisants are discharged svia the normai plant vent stack. Furthermore,

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the"guidelinesj of. this' Regslatory Guide regarding' the generation of solid waste

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Jduring operation of ; SDS will be ' followed.

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= 1The' system design' andi operation has been evaluated :and ' the determinatica

' has 1been made = that the radiological. consequences of potential unexpected c Jand uncontrolled releaseslof. radioactivity are a small fraction of' the 10CFR100

guidelines.

: Our submittal ( to you,;TLL. 251, Edated Mayi27, 1980, provides our analysis 1of the hypothetical taccidents presented in the TER.

This analysis c documents that even potential. uncontrolled and unexpected releasees of gaseous.

radioactivity -are acceptable and are below the guideline limits of' 10CFR100.

In our opinion, twe:ha 'a provided Ehe necessary information to you to enaMe 2

your review and evait tion;of our proposed change. TAlthough this change.is 7

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temporary 'in nature,1we believe that:a thorough review of the safety signi-

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. ficance of ;syst'em implementation is required.J - The. results of our review were transmitted. to youliniour TER.

1 Essentially,~.we have conbluded the following':

[17 - The operatioi ' of)SDS is not anlunreviewed safety question from. the point:

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of viewcof s in :reasing the probability' of occurrence or :the' consequences of-

.an accident lo.: malf unction -of: equipment important to ' safe tyj previously:

evaluated finitheL safety analysis report. Ths influent waters to be pro-

. cessed.by"SDS, will? be batch processed into Ithe tank farm tanks. In the' i

case ' of. stump wa ter; the' containment. boundary will be-broken for the - dura-

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' tion of the watier transfer. In reality, processing the containmee. sump water via SDS represents a; smaller hazard'than allowing it to. remain in the W

contaitunenth sump. Letdown *fros' the RCS into. the tank will be compensated gt.

for' by suitable; makeup ~ to,the RCS.. ~ Ineither case, ' operational-procedures -

to administratively eontroli hef processing (of 'sumpf or RCS water. by ~ the ~

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t iSDS;willibetis' sued :lto Lthe NRC forith'eir review and approval. -

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- ~ 2. c 2 The-operatien of$ SDS iis' notl an ; unr'eviewedisafety. question from the point i

oc c:nof Lview of fereatingithe possibility 1for an. accident'_ or malf unction-of Ja'fdiffer'entityp'e; than'any evaluated previously;in the safety analysis t

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. report.. jPotentiaEhypothetical; accidents,'as discussed in the' SDS' TER,

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'As, Iresultziniconsequencesino more severe: than.the consequences associated :

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' _ LwithTthe maximum hypothetical:' accident postulated' in; the TMI Final' k..,

• lSafetyfAnalysis1RepottC(FSAR).:/Therefore the" consequences of hypothetical'

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-.SDS ' Accidents are.within[the. umbrella 'of ~ accidents prov'ided in. the FSAR.

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J. T. Collins' TLL 4 78 3.

The operation of SDS is not anticipated to cause a reduction in the margin of safety as defined in the basis for any technical specification. The SDS-does not provide for a liquid ef fluent pathway to the environment.

The gaseous pathway contributes to a dose rate at the site boundary of less than:

5 mrem /yr. to the whole body or any organ from radionuclides except a.

I-131 and particulate nuclides with half lives greater than 8 days, and b.

15 mrem /yr. by inhalation or to the thyroid of a child through the cow-milk chain from I-131 and other particulate radionuclides with half lives longer than 8 days.

These limits are objectives as stated in the TMI-2 Interim Recev ery Technic al Specifications Appendix B, to be achieved and the subsequent limits concerning gaseous ef fluents.

Furthermore, as stated in the bases for the Appendix B Technical Specifications, the resulting annual exposure rate from noble gases at any 12 cation at the site boundary will not exceed 10 millirenc per year.

Section 6.3.2 of the SDS TER provides the analytical basis and methodology employed to assure that the of f-site radiological exposure does not represent a reduction La the margin of safety for operation of the SDS.

Currently, TMI-2 PORC is reviewing the SDS system including system desiga operation and maintenance to verify that the operation of the system does present an "unreviewed safety question". The results of this review will not be fo rwarded to you when it becomes available. However, the results of this review are not expected to provide results that exceed the upper bounds of projected, consequences of SDS operation as presented in the TER.

Therefore, we continue to maintain that the TER provides infermation that is adequate to enable your safety analysis of SDS.

In summary, we recognize that a safety evaluation in the SDS is required by 10CFR50.59 and we intend to submit such a document by December 1, 1980. However, we wish to emphasize that all of the elements of the safety evaluation have been addressed in our previous submittals, which you have had in-hand since April of this year. We do not perceive any need for extension in NRC review i

schedule, associated with our submittal of the Safety Evaluation.

Sincerely,

/S/ G. K. HOVEY G. K. Ho,y Vice-President and Director, TMI-2 GKH:LJL:lh cc:

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