ML19344E808
| ML19344E808 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/29/1980 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Parker W DUKE POWER CO. |
| References | |
| NUDOCS 8009110636 | |
| Download: ML19344E808 (8) | |
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Docket Nos.: 50-369/370 Mr. William 0. Parker, Jr.
Vice President - Steam Production Duke Power Company Post Office Box 33189 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Parker:
Subject:
RadwLste Management System (McGuire Nuclear Station, Units 1 & 2)
As a result of our review of Revision 39 to the McGuire Final Safety Analysis Report we require some additional information which is described in Enclosure No. 1.
In Enclosure No. 2, we have provided our positions and comments on the Radiological Effluent Technical Specifications and the Offsite Dose Calculation Manual.
Enclosure No. 3 requests information regarding the Process Control Program.
To be acceptable, your response must address plant personnel duties, dewatered resin packaging (if applicable), and indicate your review and approval of the Process Control Program.
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We ;equest that this Information be provided no later than August 15, 1980.
Sincerely, 5 e. =
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Robert L. Tedesco, Asristant Director for Licensing l
Division of Licensing l
Encls:
As Stated i
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Mr. William O. Par ker, Jr.
g Vice President, Steam Production 0
Duke Power Company P. O. Box 2178 422 South Church Street I,
Charlotte, North Carolina 28242 i
Mr. W. L. Porter cc:
Duke Power Company David Flesichaker, Esq.
P. O. Box 2178 1735 Eye Street,'N. W.
422 South Church Street Suite 709 Charlotte, North Carolina 28242 Washinoton, D. C.
20006 l
Mr. R. S. Howard Richard P. Wilson, Esq.
Power Systems Division Assistant Attorney. General Westinghouse Electric Corporation State of South Carolina P. O. Box 355 2600 Bull Street i
Pittsbur gh, Pennsylvania 15230 Columbia, South Carolina 29201 i
Mr. E. J. Xefth EDS Nuclear Incorporated i
220 Montgomery Street San Francisco, California 94104 Mr. J. E. Houghtaling NUS Corporation 2536 Countryside Boulevard Clear water, Flor ida 33515 Mr. Jesse L. Riley, President The Carolina Environmental Study Group 854 Henley Place j
Ch?'lotte, Nor th Carolina 28207 J. Michael McGarry, !!!, Esq.
Debevoise & Libern.an t
1200 Seventeenth Street, N. W.
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Washington, D. C.
20036 I
Rober t M. Lazo, Esq., Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Cadet H. Hand, Jr., Director Bodega Marine Lab of California P. O. Box 247 j
Bodega Bay, California 94923 l
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Mr. William O. Parker, Jr.
3.
I cc: David Flesichaker, Esq.
1735 Eye Street, N. W.,
Suite 709 Washington, D. C.
20006 Richard P. Wilson, Esq.
Assistant Attorney General State of South Carolina 2600 Bull Street l
Columbia, South Carolina 29201 Office of Intergovernmental Relations 116 West Jones Street 4
j Raleigh, North Carolina 27603 I
County Manager of Mecklenburg County 720 East Fourth Street Charlotte, North Carolina 28202 U. S. Environmental Protection Agency ATTN: EIS Coordinator Region IV Office 345 Courtland Street, N. W.
Atlanta, Georgia 30308 e
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i ADDITIONAL QUESTIONS FROM ETSB ON THE FSAR FOR MCGUIRE NUCLEAR STATION, UNIT NOS 1 AND 2 Docket Nos. 50-369 and 50-370 1)
Revision 39 to the FSAR, page 11.5-9, refers to an evaporator concentrates batch tank and an evaporator concentrates storage tank. Provide the building plan and elevation location for these tank's.
2)
Revision 39 to the FSAR, page 11.2-4a, refers to a Radwaste Facility Sub-system containing a 50,000 gallon Auxiliary Floor Drain Tank, a 50,000 gallon Auxiliary Waste Evaporator Feed Tank, associated lines, pumps and sump. The tanks are described as seismic. Provide the building plan and elevation for this radwaste equipment. Provide the analysis that shows that this major change to the radwaste system meets the guidelines of Regulatory Guide 1.143, as required by the acceptance criteria given in SRPs 11.2.11 and 11.3.II (Rev.1).
3)
Revision 39 to the FSAR, page 11.2-4a, refers to a Contaminated Warehouse Subsystem containing laundry and decontamination equipment; This equipment is part of the radwaste management systems. Provide the building plan and elevation for the change. Provide the analysis that shows that this major change to the radwaste system meets the guidelines of Regulatory Guide 1.143, as required by the acceptance criteria given in SRPs 11.2.11 and 11.3.11 (Rev.1).
4)
The evaluation in 15.5.5 of the FSAR does not address storage tank rupture or liquid overflow from tanks not located in the Auxiliary Building. Pro-vide the information required by the acceptance critaria in SRPs 15.7.2.11 and 15.7.3.II, for tanks added by Revision 39.
5)
Revision 39 refers to a Waste Shipping Pad (page 11.5-7). Figure 11.5.3-2 indicates that the pad drains to the yard service drain.
Indicate what controls have been included to assure that liquid spills, overflow and drainage duringmobile solidification or spent resin dewatering operations are collected and raturnec to the radwaste management system. Provide a Figure indicating the location of lines, instruments, equipment and rad-waste connections for themobile equipment in this area. Provide your equip-ment interface with the process control program for solidification and dewatering operations.
6)
Revision 39 refers to a 6000 gallon binder' storage tank (page 11.5-4).
Provide the location of this underground tank and its associated lines and pump, as related to other structures. Evaluate the hazards of binder storage and discuss the fire protection provisions and controls to mitigate flames and other ignition sources. Describe the materials of construction, toxic limits, temperature controls and ventilation for storing and handling the binder liquid.
Is the tank located in an underdrain area or covered at grade level?
7)
Revision 39 Figure 10.4.8-3 has been changed to show that there is no di-rect effluent from the steam generator blowdown system. Sections 11.4.2.1.4, 10.4.8.2.1 and Table 11.4.2-1 refer to EMF-32 as an effluent monitor.
Is EMF-32 a recycle process monitor? Clarify the use of the word " effluent".
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Revision 39 may need edit changes. We find that page 11.5-2 should be Rev. 10 (not Rev. 8); page 11.5-3 should be Rev. 10 (not Rev. 0);
Table 11.1.1-1 (sheet 1 of 2) should be on the back side of page 11.6-6, Rev. 39. Please clarify.
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ETSB PS0ITIONS AND COMMENTS ON THE RETS AND ODCM FOR MCGUIRE NUCLEAR STATION,. UNIT NOS. 1 AND 2 Docket Nos. 50-369 and 50-370 1)
Changes to the standard definition on SOLIDIFICATION are not acceptable.
We have reviewed the FSAR through Revision 39 and the proposed PCP and find no justification for changing the standard definition. Solidification app-lies to evaporator bottoms, boric acid solutions, chemical wastes, filter sludge, spent resin, and (whenever chemical waste pond discharges are not permitted) the filter /demineralizer slurry. Dewatered spent resin or resin slurry in high integrity containers are " packaged", not solidified.
Ref: RETS pages 1-7, 3/4 11-20 and 3/4 11-7A..
(See additional questions on the PCP,' item 1, in Enclosuro 3.)
2)
The following changes to the liquid ano gaseous monitoring instrumentation are not acceptable, a)
Pump curves are not flow devices.
It is our position that you should have a device that measures minimum RC discharge in order to take credit for inplant dilution in establishing set points on effluent monitors in the ODCM. We have suggested a flow switch, flow meter, weir level, pump discharge sensor, motor amp-switch or computer alarm on minimum RC pumps running, Clarify the device to be used for this requirement.
Ref: RETS pages 3/4 3-66 and 3/4 3-71.
b)
The monitor EMF-44 provides automatic termination of containment ventila-tion unit condensate releases at the established set point, per FSAR, Table 11.4.2-1 and the ODCM. As such, footnote 1 is applicable for the channel functional. test on systems witt. automatic isolation. The change to footnote 2 is not acceptable.
Ref: RETS page 3/4 3-70.
c)
Two oxygen analyzers are required in Tables 3.3-13 and 4.3-13 of the RETS.. We have reviewed the FSAR through Revision 39. Our position is given in SRP 11.3 (Rev. 1). Section 11.3.3.2 of the FSAR specifies that there are four on line gas analyzers (shown on Figure 11.3.2-5).
The change to one oxygen analyzer is not acceptable. We require action to be taken whenever the oxygen concentration exceeds 2% by volume as 4
given in SRP 11.3 (Rev. 1), therefore, the change to 3% by voiume is not acceptable in the RETS.
Ref: RETS pages 3/4 3-74, 3/4 3-79 and 3/4 11-17.
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3)
The standard RETS has adopted a limit, above which use of the radwaste treat-ment system is required to meet 10 CFR 50.36a. Our bases for the limiting values is given and our positicn has not changed. The change to higher
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projected dose levels is not acceptable. The change to the surveillance requirement to exclude projections when the system is not operable would also exclude demonstrating how you plan to meet the LC0 and, therefore, the change is unacceptable.
Ref: RETS pages 3/4 11-6 and 3/4 11-14.
4)
Na justification has been provided for the change to delete tritium grab Samples frem the ventilation exhaust from the spent fuel pool area. We have discussed sample locations to resolve this sampling requirement. Deletion is not acceptable.
Ref: RETS page 11-11.
5)
The liquid and gaseous off-line effluent monitors and samplers should be described in the ODCM as having min; mum flow alarm levels (flow switches).
We need this information to complete our review.
Ref: ODCM section B.3.0.
6)
In connection with item 3, above, we have reviewed your methodology for de-termining dose impact for projecting when to use radwaste treatment system equipment. We find that the simplified equations are based on conservative estimates and averaged concentrations for estimated releases of certain nuclides based on continuous use of all radwaste treatment equipment over the life of the plant. The equation calculates a constant rate with zero rate of change. This plan is not representative of real releases.. For example, Cs-134 and Cs-137.are generally low during the first years of opera-tion; the ratio of Cs-134 and Cs-137 to othar nuclides varies.with the treat-ment method, segragation of fluid streams, fission product generation and release mechanisms; and many long term and short term operational variables are not represented by Cs-134 and Cs-137 concentrations alone. The same general arguments hold for the radioactive materials in gaseous effluents.
In the RETS, we have allowed a variable rate, but set a limit (above which the radwaste equipment must be used) on the fixed rate of change. Since the cumulative dose calculations are computerized at your facility, the simplest method would be to update dose calculations at l'ast once every 31 days, e
maintaining plant records on operational, release aad treatment conditions to use for projection purposes as gi.en in the surveillance requiren'ents.
As stated in NUREG-0133, some nuclides which take more than 31 days to identi-fy, may be estimated for projection purposes, only. We need your response in order to complete our review.
Ref: ODCM section B.4.0.
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QUESTIONS FROM ETSB ON THE PCP FOR MCGUIRE NUCLEAR STATION, UNIT NOS. 1 AND 2 Docket t/os. 50-369 and 50-370 1)
The Process Contros Progran (PCP) for EkGuire Nuclear Station submitted July 8, 1980, does not address dewatered spent resin (FSAR 11.5.3.2) pro-cessed to the shipping container without solidification. The FSAR includes the solidification statement, "if required". Therefore, you should provide the PCP to assure.that dewatered spent resins can meet the free-water criteria, and describe the methodology and steps to be taken to assure that the plant and/ortzbile equipment can produce a product that will be acceptable at the burial site.
2)
The PCP does not address the interface between facility personnel and the contract personnel. For example, who approves plant. connections for mobile unit operation? Who approves adjustments to the solidification parameters?
Who provides inspection of solidification product? What plant records are to be submitted by contract personnel? Who establishes batch input data and approves batch calculations? Who obtains samples for test verification?
Who assures quality control of the solidification chemicals? Who calculates radioactive content and limits occupational exposure? Who specifies when pretreatment is required, how much and what chemical will be used?
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