ML19351D301
| ML19351D301 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/17/1980 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| TAC-44454, NUDOCS 8010090488 | |
| Download: ML19351D301 (6) | |
Text
E p ren,
[/
f,j UNITED STATES NUCLEAR REGULATOHY COMMISSION 3
E WASHINGTON, D. C. 20555 4
4
,o 9 *****
September 17, 1980 Docket Nos. 50-213 SQ=24fi Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
SUBJECT:
POST-ACCIDENT SAMPLING CAPABILITY (TMI Item 2.1.8.a) FOR HADDAM NECK PLANT AND MILLSTONE UNIT NOS. 1 AND 2 We have reviewed your letter of June 23, 1980, concerning the proposed design of post-accident sampling and analysis systems for Haddam Neck, Unit No.1, and Millstone, Units 1 and 2.
We concur in deleting the rcquiremant for obtaining pressurized simples but we take exception to 1
your interpretation of the intent of NRC requirements.
Our response to your letter is contained in the enclosure to this letter.
Note that we have enumerated our response consistent with your submittal.
S'ncerely, t
- 3l ld d Dennis M. Crutchfield Chief i
I Operating Reactors Branch #5 Division of Licensing
Enclosure:
As stated cc w/ enclosure:
See next page 8o lo o 9 0'lTT
/
A Mr. W. G. Counsil 2-September 17, 1980 4
cc w/ enclosure:
William H. Cuddy, Esquire Connecticut Energy Agency L
Day, Berry & Howard ATTN: Assistant Director
-Counselors at Law Research and Policy One Constitution Plaza Development Hartford, Connecticut 06103 Department of Planning and Energy Policy Board of Selectmen 20 Grand Street Town Hall Hartford, Connecticut 06106 Haddam, Connecticut 06103 Director, Technical Assessment Division Northeast Nuclear Energy Company Office of Radiation Prograas AT16: Superintendent (AW-459)
Millstone Plant U. S. Environmental Protection P. O. Box 128 Agency Waterford, Connecticut 06385 Crystal Mall #2 Arlington, Virginia 20460 Mr. James R. Himmelwright Northeast Utilities Service Company U. S. Environmental Protection P. O. Box 270 Agency Hartford, Connecticut 06101 Region I Office ATTN: EIS COORDINATOR Resident 7.nspector JFK Federal Building c/o U. S. NRC Boston, Massachusetts 02203 P. O. Box Drawer KK Niantic, Connecticut 06357 Superintendent Haddam Neck Plant Waterford Public Library RFD #1 Rope Ferry Road, Route 156 Post Office Box 127E Waterford, Connecticut 06385 East Haapton, Connecticut 06424 First Selectman of the Town Resident Inspector of Waterford Haddam Neck Nuclear Power Station dall of Records c/o U.S. NRC 200 Bcston Post Road East Haddam Post Office Waterford, Connecticut 06385 East Haddam, Connecticut 06423 Jchn F. Opeka Systems Superintendent Northeast Utilities Service Company P. 0. Box 270 Hartford, Connecticut 06101 Natural Resources Defense Council 917 15th Street, N. W.
thshington, D. C.
20005
x----------
a
ENCLOSURE f
N I
POST-ACCIDENT SAMPLING SYSTEMS (TMI ITEM 2.1.8.a)
HADDAM NECK PLANT MILLSTONE STATION UNIT NOS. 1 AND 2 4
_ Item 1-Our letter dated October 30, 1979 states that the licensee shall have the capability to promptly obtain (in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) pressurized and unpressurized reactor coolant samples and a containment atmosphere (air) sample.
CYAPC0 - NNECO Comment It is possible that reference to the terms " pressurized and unpressurized" could apply to either the reactor coolant system from which the sample is obtained or to the sample itself.
The appropriateness of the capability to obtain samples from a pressurized or unpressurized reactor coolant system is easily recognized, and it is our intent to design the system accordingly.
However, there is no apparent justifi-cation for designing the capability to process pressurized samples.
Under the post-accident source terms specified, pressurized samples represent an unnecessary safety concern due to possibility of leakage i
from the sample container and the potential for flashing of the sample.
In light of the above considerations, it is CYAPCO's and NNEC0's intent to install a sampling system capable of obtaining samples from either a pressurized or unpressurized reactor coolant system and all samples will be unpressurized.
NRC Response We agree with CYAPC0 and NNEC0 with respect to the requirement for the capability to obtain pres'surized samples. A staff position on this same item was to be included in a clarification letter dated September 5, 1980.
In the clarification, it was stated that licensees have the option of 4
obtaining either a pressurized sample or an unpressurized sample, provided that in the latter instance there exists the capability to determine total dissolved gases.
)
Item 2 We requested quantification of the foilowina:
1.
certain isotopes that are indicators of the degree of core damage-(i.e., noble gases, iodines and cesiums and non-volatile isotopes),
r
.c g,
r
..,,,or J
2.
hydrogen levels in the containment atmosphere in the range O to 10 volume percent, dissolved gases (i.e., H, 0 ) and boron concentration of 3.
2 2
liquids.
gy CYAPC0 - NNECO Comment Recent discussions with the NRC Staff have revealed that the intent r / the requirement regarding dissolved gas refers to only total
.issolved gases and not an individual species identification.
The basis for this position is that the safety concern relates to the rate cf formation of a gas bubble and not to the possibility of a hydrogen explosion.
In light of the above considerations, it is CYAPC0's and NNEC0's intent to install a system with the capability to determine total dissolved gas only.
Hydrogen or oxygen or other species identification will not be made available.
NRC Response The CYAPC0 and NNECO citation notes three separate items, while the discussion centers on only one of the three.
-Subpart 1 of the citation is applicable to samples of both primary coolant liquid and containment air and the NRC staff position remains that isotopic identification and quantification of both are required.
Subpart 2 of the citation is applicable to containment atmosphere air and the NRC position remains that hydrogen levels be measured in the range of 0 to 10 volume percent.
Subpart 3 of the citation is applicable to primary coolant liquid and is the only portion of the citation which has been changed by the September 5, 1980 clarification letter. The clarification specifies that the licensee has the choice of measuring either total dissolved gases or dissolved hydrogen and that measurement of dissolved oxygen is recommended but not required. The staff's position includes a requirement for measurement of chloride in the primary coolant but contains a modifying statement to the effect that if a plant has a closed cycle or intermediate cooling loop between the cooling water supply and primary coolant loops, then chloride dnalysis within four days is acceptable and may be performed offsite.
i
~, -
O A
To surrmarize and re-state the staff's position re19tive to the items discussed above, CYAPC0 and NNEC0 should provide c post-accident sampling and analysis sytem that will accomplish the following:
1)
For primary coolant fluids and for containment atmosphere air, provide the capability for the isotopic identification and quantification of the principal radionuclide. expected to be present under accident conditions.
2)
For containment atmosphere air, provide the capability of measuring hydrogen concentrations in the range 0 to 10 volume percent.
- 3) Fm primary coolant fluids, provide the capability to treasure 1
or determine either (a) total dissolved gases, or (b) hydrogen.
Measurement or detennination of oxygen is recommended but i
not required. Also provide, for primary coolant fidds, the capability for chemical measurement or determination of boron (PWRs only) and chloride. The boron analysis results should be available with~in three hours from the time a decision is made to take a sample. The chloride anal able within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if a plant both (a) ysis should be avail-uses salt or brackish water for cooling and (b) does not have closed intermediate loop cooling (i.e., only one barrier between primary coolant and salt or brackish water; otherwise a chloride analysis should be available within four days.
In either case above, the chloride analysis need not be done onsite.
- 4) The staff encourages the use of inline analytical equipment which is capable of providing "real-time" results; notwithstanding, the staff requires that post-accident sampling systems be capable of providing " grab samples" of both reactor coolant fluids and containment air for the specific purposes of: (a) providing
" backup" samples for analysis in the event of instrument failure or malfunction; (b) providing samples for analysis of factors not provided by the design of the system; and (c) providing samples for confirmatory analysis by Federal and State agencies or by such consultants as may be engaged by the licensee. The post-accident sampling system should be capable of providing at least one sample per day for both primary coolant fluid and containment atmosphere air for seven days following the onset of the accident and then onc saniple of each per week for as long as the accident situation exists.
A
_4_
i Item 3 NRC letter dated October 30, 1979 specifies a requirement to perform chemical analyses on the primary coolant other than dissolved gas, boron concentratien, and activity.
CYAPC0 - NNECO Cor. ment Recei,c discussions with cognizant industry personnel have suggested that sampling system recuirements may ultimately include other chemical analyses, such as pH n
.aloride concentration.
CYAPC0 and NNEC0 do not believe that these additional provisions are necessary and as such, chemical analysis capability will include only disso'.ved gas, boron, and activity analyses.
NRC Response The staff's position on requirements for chemical analysis capability is stated in the response to Item 2, above.
CYAPC0 and NNEC0 should have the capability to perform, or to have contractual arrangements for the performance of, analysis of liquid coolant samples for chloride.
Forthcoming F.evision 2 of Regulatory Guide 1.97 contains a recommendation for the capability of performing pH measurement of primary coolant.
Item 4 We state, in our letter dated October 30, 1979, that procedural changes and/or plant modifications must assure that it shall be possible to obtain and analyze a sample while incurring a radiation dose to any individual that is as low as reasonabely achievable and not in excess of GDC 19.
CYAPC0 - NNEC0 Comment The limit for GDC 19 is 5 rem whole body which corresponds to 75 rem extremity dose.
Cognizant industry personnel have suggested that the design requirements are 3 rem whole body and 18.75 extremity dose.
Please be advised that CYAPC0 and NNECO are designing the ree+am to comply with GDC 19 criteria with the use of ALARA guidelines is also noted that one individual may receive up to 5 rem to onto1n the sample and another individual may receive up to 5 rem to analyze the sample.
NRC Response The September 5, 1980 clarification letter cites the 5 rem dose limit of GDC-19 as the design basis for all phases of the sampling and analysis processes of the post-accident sampling system.
Please be aware, however, that the 5 rem limit pertains to the total integrated dose to an individual for the duration of an accident and is not limited to one specific task.