ML20002D553
| ML20002D553 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/13/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| TASK-05-10.A, TASK-5-10.A, TASK-RR LSO5-81-01-016, LSO5-81-1-16, NUDOCS 8101210337 | |
| Download: ML20002D553 (7) | |
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Docket No. 50-213
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Mr. W. G. Counsil, Senior Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
RE: HADDAM NECK SEP TOPIC V-10.A, " RESIDUAL HEAT REMOVAL SYSTEM HEAT EXCHANGER TUBE FAILURES" In a letter dated February 28, 1979, the staff provided to you a draft evaluation of Systematic Evaluation Program Topic V-10.A, " Residual Heat Removal System Heat Exchanger Tube Failures." In that letter you were requested to examine the facts upon which the evaluation was based and respond by either confirming that the facts are correct or by identifying any errors. Your response dated April 12, 1979 provided comments on the draft evaluation indicating that the draft was incorrect.
You stated that the staff's statement regarding the lack of chemistry limits and surveillance requirements for primary coolant chemistry is not correct. You further stated that existing plant Technical Specifica-tions 3.2, " Reactor Coolant System Activity" and 4.2, " Operational Safety Items" establish activity limits and minimum surveillance requirements for reactor coolant system chemistry. You also determined that the remainder of the draft evaluation is correct and concurred with the overall findings regarding current criteria.
We have reviewed the plant technical specifications and have found that our safety evaluation is substantially correct. Although Haddam Neck Technical Specification 3.2 contains a limit on the primary coolant system act!vity, this limit is for the purpose of limiting the offsite dose consequences of a steam generator tube rupture. There are no chemistry limits contained in the specification as required in Standard Review Plan (SRP) 5.2.3.
Specification 4.2 does require a radio-chemical analysis of the reactor coolant at a frequency of 5 days / week (Table 4.2-2, " Minimum Equipment Check and Sampling Frequency"), however, the lack of testing for the chemical concentrations precludes determination of chemical impurities which are significant with respect to corrosion and system integrity. We have not changed our conclusion contained in our evaluation that the current sampling required by plant procedures is not adequate.
Enclosed you will find our final evaluation which reflects the items mentioned above.
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F JAN 13 1980 Mr. W. G. Counsil '
It is our understanding that you are intending to implement the Standard Technical Specifications (STS) for the Haddam Neck facility. The STS j
provide chemistry limits and an acceptable surveillance frequency. Upon implementation of STS at Haddam Neck the coolant sampling requirements would be in compliance with our requirements.
Sincerely, i
Dennis M. Crutchfield, Chief Operating Reactors Branch f5 Division of Licensing
Enclosure:
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ENCLOSURE 1
SYSTEMATIC EVALUATION PROGRAM PLANT SYSTEMS /MTERIALS HADDAM MECK l
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Topic Y-10.A Residual Heat Removal System Heat Ex: hanger Tube Failures l
i The safety objective of this review is to assure that impurities from the cooling water system are not introdu:ed into the primary coolant '
in the event of residual heat removal system heat exchanger tube failure.
This was expanded to assure that adequate monitoring exists -
to assure no leakage of radica:tive material in the ether dire: tion -
into the service water and thus to the environment.
Information for this assessment was gathered from. plant personnel during the safe shutdown review site visit in July 1978 and from related tele-phone conversations. Information was also taken from the Haddam Neck Te:hnical Specifications and the Haddam Neck Final Safety Analysis Report.
The bases for the review of these cooling systems on toda'y's plants include:
(1) the NRC's Standard Review Plan (SRP) 9.2.1, which requires that the service water system include the capability for dete: tion and control of radioactive leakage into and out of the system and prevention of a::idental releases to the environment; (2) SRP 9.2.2, which requires that auxiliary cooling water systems (su:h as the residual heat removal system) in:1ude provisions for detection, colle: tion and control of system leakage and means to. detect leakage of activity from one system *a another
'and preclude its release to the environment; and (3) 3RP 5.2.3, which discusses compatibility,of materials with reactor coolant and requires monitoring and sampling of the primary coolant system. These Standard Review Plans were used only in the compari. son of Haddam Ne:k against i
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today's criteria and were not used as licensing requirements which must be
. met, especially if the plant incorporates other equally acceptable means of accomplishing the stated goals.
Unlike the state ent of the problem in the topic definition Haddam Neck's residual heat removal (RHR) system would normally be at a higher pressure than the closed cooling water (CCW) system which cools it.
The CC).' system operates at a higher pressure than the service water gystem, which cools the CCW heat exchanger and forms the ultimate heat sink.
It is noted here only for information that service water would be used directly to cool the two RHR heat exchangers during post-Loss of Coolant Accidene (LOCA) conditions. This presents no concern to us for the purpose of this review, since cleanup from the highly unlikely LOCA, for possible return to service, would include flushing of the. primary system
.and detailed systems inspection.
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Aicording to plant sources, the lowest pressure on the primary side of the two RHR heat exchangers is approximately 100 psig when the primary system is depressuri:ed and the reactor head removed. Even when the RNR system j
.is being shut down after use (and thus during startup), pressure at the heat exchangers remains above that of the CCW system, which operates at l
l pressures between 83 and 85~ psig at these heat exchangers. Thus it is l
readily seen that if tube leakage were to occur, its direction would be from the primary coolant system to the CCW sys*am.
Eventhoughthisisthecase,presentNRCguidance(SRp5.2.3) requires monitoring and sampling of the primary coolant system. This is especially, important since the Haddam Neck licensee has requested that the applicable Technical Specification be amended to allow short-tern RHR system shutdowns l
during certain refueling outage evolutions, to decrease turbulent flow around.
the fuel assemblies. During these periods, leakage from CCW to the RHR systerr l
could occur. Haddam Neck procedures do presently require sampling of the h
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. primary system three times per day when the RHR system is in operation.
This sampling program checks for baron concentration, pH, conductivity, chlorides, and includes a gamma analysis for coolant activity. There is also a semi-annual RHR inservice inspection chemical analysis program and a sampling program for RHR system leakage. However, the Haddam Neck Technical Specifications (TS) do not presently contain any chemistry limits for primary coolant chemistry. The existing TS do contain a limit for primary system activity but none for dissolved chemicals such as chlorides or fluorides. Therefore, the licensee does not conform to SRP 5.2.3 which requires limitations on the concentrations of impurities in the reactor coolant and monitoring on a scheduled basis. The licensee does have a technical specification which requires a periodic radio-chemical analysis of the coolant, but this specification is useless for monitoring dissolved chemicals if no limit exists for the chemicals.
As a means of detecting leakage into (from RHR system or other cooled components) or out of [to the RHR system (highly unlikely) or to the service water system] the CCW system, the CCW system surge tank incor-porates high and low level alarms which annunciate in the plant's main control room [ Final Safety Analysis Report, Section 5.2.3.2].
- Also, leakage of radioactive material from the RHR system heat exchangers (or any other CCW-cooled component) would be monitored and alarmed by the CCW system's continuous, radiation m nitor which is on the CCW pumps' suction piping. CCW system sampling is performed once per week in accordance with Slant procedures. The sampling program includes pH, conductivity. chropate (a compound of which is used for corrosion inhibition), gar =a scanning, and a tritium analysis.
f As noted above, the CCW heat exchangers (two) are cooled by the servic'e water system. According to. plant sources, CCW pressure at these he'at exchangers is between 83 ar.d E5 psig, with service water opera' ting between 55 and 70 psig. Thus any tube leakage would result in CCW 1eakage to the' environment. Also, although it would take highly unlikely undetected simultaneous leakage from the RHR heat exchanger (s) (or any other CCW-cooled component) and the CCW heat exchanger (s) in order for radioactive material to escape to the environment, prudent design, as dictated by SRP 9.2.1, would require the installation of a radiation Haddam Neck's service detector and alarm en the service water system.
water system does incorporate such a detector and alarm, as noted in Appendix B Technical Specification Table 2.4 3, with calibration require-ments stated in Appendix B Technical Specification 2.4.2.6.
Therefore, with the exception noted above, we have found that the Haddam Neck plant meets today's criteria. With regard to the question of Technical Specifications, no action on the part of the licensee is required at this time.
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