ML20030D635

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Forwards Draft SER on FSAR Sections Re Effluent Treatment Open Issues.Info Requested by 811015
ML20030D635
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 08/27/1981
From: Schwencer A
Office of Nuclear Reactor Regulation
To: Davidson D
CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8109140075
Download: ML20030D635 (31)


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Hr. Palwyn R. Davidson i

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UNITED STATES g

NUCLEAR REGULATORY COMMISSION Lt j

.j j WASHINGTON, D. C. 20555

\\+...#.Y Nf6 2 7 1981 J

Docket Nos.

50-440/441 Mr. nalwyn R. Davidson Vice president - Engineering The Cleveland Electric Illuminating Comoany

o. n. Gox 5000 Clevel and, Ohio 44101 near Mr. Davidson:

Suaiect: Request For Resolution Of Open Issues-Effluent Treatment In the oerformance of the Perry licensing review, the staff has prepared a draft Safety Evaluation Report (SER) on sections 6.5.1, 10.4.2, 10.4.3, 11.0 thru 11.4, and 15.7.3 of the FSAR.

A opy of this draft is enclosed for your review. Open issues pertaining to the staff review are identified in the draft SER and these will serve as the basis of our request.

'4e request that you provide the information not later than October 15, 1981. If you require any clarification of this request, please contact M. D. Houston, Pro.'act Manager, (301) 492-8593.

Sincerely,

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i i ;'b:df( w A. 'Schwencer, Chief Licensing Branch No. 2 Division of Licensing 1

Enclosure:

Reouest for Additional Information cc w/ enclosure:

See next oage

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i Mr. Dalwyn R. Davidson Vice President, Engineering The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 I

cc: Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.

Washington, D. C.

20036 Donald H. Hauser, Esq.

Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 U. S. Nuclear Regulatory Commission Resident Inspector's Office Parmly at Center Road Perry, Ohio 44081 Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 s

Tod J. Kenney 228 South College Apt. A Bowling Green, Ohio 43402 Daniel D. Wilt Wegman, Hesiler & Vanderberg 7301 Chippewa Road, Suite 102 Brecksville, Ohio 44141 Jeff Alexander 920 Wilimington Ave.

Dayton Ohio 45420 Terry Lodge, Esq.

915 Spitzer Building Toledo, OH 43604 I

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DRAFT SER FOR PERRY l and 2 1

460.0 EFFLUENT TREATMENT SYSTEMS BRANCH 6.5.1 ESF ATMOSPHERE CLEANUP SYSTEMS

,l The review performed under Standard Review Plan 6.5.1 pertains to the filtration and cleanup systems provided by the applicant for the. purposes of (1) controlling.the releases of radioactive material in plant gaseous effluents (radioiodine and particulate material) and (2) controlling the concentrations of radioactive material in the recirculated control room atmosphere within habitable limits following a design basis accident (DBA).

In the P'erry Nuclear Dower Plant, Unit No.1, design, there are three filtration systems designed for these purposes: (1) the Control Room Emergency Recir-culation System (CRERS); (2) the Fuel Handling Area Charcoal Exhaust System (FHACES); and (3) the Annulus Exhaust Gas Treatment System (AEGTS). Our review was concerned with the design of system.com-ponents, design features which influence system availabili+y and reliability, aild the design efficiency of media installed in the atmosphere cleanup systems for the removal of radioactive materials i

from the process or ef fluent stream.

I.

DESIGN OF ESF ATMOSPHERE CLEANUP SYSTEMS The CRERS, FHACES, and AEGTS are safety related systems. The system designs confonn to the requirements of GDC 1, 2, 3, 4, 19, 60, and 61 of Appendix A to 10 CFR Part 50. The guidance in Regulatory Guide 1.52 nas been considered in the design of these systems. One deviation from full confonnance with 1

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a R.G.1.52 has been noted; however, the deviation was considered j

acceptable design practice at the design stage and, therefore, continues to be acceptable to the staff at this time. Posi-tion C.5.k of R.G.1.52 and ANSI N509-1976' ' recommend that means

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be provided for preventing possible iodine desorption and ad-sorbent autoignition that may result from radiation-induced heat in the absorbent and any accompanying temperature rise. Accept-able designs include low-flow air bleed systems, cooling coils, water sprays for the adsorber section, or other cooling mechanisms.

Rather than a cooling system to prevent autoignition, the ap-plicant has provided a water deluge spray system for flooding the adsorbers to extinguish fires in the adsorbers; the system is manually actuated from the control room on the basis of high temperature alarms from sensors within the charcoal beds.

Design of the CRERS, FHACES, and AEGTS is to seismic Category 1 and to pertinent sections of ANSI N509 and ERDA 76-21, as out-lined in Regulatory Guide 1.52.

Redundant trains are provided

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for each system. Charcoal adsorbers are of the integral type, with top loading and bottom unloading of bulk charcoal.

II. TESTING 0F ESF ATMOSPHERE CLEANUP SYSTEM COMPONENTS Testing of ESF atmosphere cleanup systems and components is in accordance with the provisions of Regulatory Guide 1.52.

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- Air flow distribution is in accordance with Position C.S.b of Regulatory Guide 1.52.

- In-place testing of HEPA filter section is in accordance with ANSI N510; however, testing criteria do not make mention of portions of Position C.5.b of Regulatory Guide 1.52, e.g., specific intervals or following painting, fire, or chemical release (may be open item or, alternatively, may be in Tech Specs).

- Leak tests of charcoal adsorber sections to use halogenated hydrocarbon refrigerant gas.

- Test canisters will be used for determination of radio-halogen retention.

460.4 OPEN ITEMS: Does not mention testing requirements for specific intervals between tests and does not specify testing following painting, fire, or chemical release.

III. INSTRUMENTATION REQUIREMENTS - ESF CLEANUP SYSTEMS A.

CRERS Instrumentation provided for the CRERS includes:

- Flow rate, unit outlet. Provides indication and high/

low alarms in the main control room. No provision for recording flow as recommended in ANSI 509 or Regulatory Guide 1.52.

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l - Temperature, charcoal bed. Provides indication and high/ low alarms in the main control room. No require-ments specified in Regulatory Guide 1.52.

- Pressure Drop (ao). Provides indication, status of operation, and alarms in main control room. Com-ponents covered include roughing filter, upstream HEPA filter, charcoal bed, and downstream HEPA filter. No provision for recording of any system pressure drops.

No provisions for measurement of total pressure drop across complete system. Regulatory Guide 1.52, Section C.2.g, recommends recording of " pertinent" pressure drops at the control room.

460 5 OPEN ITEMS: No provision for control room recording of system 460.6 air flow rates or pressure drops. No provision for measurement, indication, or recording of total system pressure drop (lapi.

460.7 No provision for status indication in control room of deluge valve positions, valve / damper operator position, or fan status.

B.

AEGTS Instrumentation provided for the AEGTS includes:

- Low Air Flow. Alarm in control room.

- Pressure Drop (ao).

Indicator (s) in control room.

(Note: Not specific in list, page 7.3-35)

- Temperature.

Indicators in control room (Charcoal bed).

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- Radiation.

Indicator in control room.

(Note: P&ID shows op sensors on prefilter, upstream HEPA charcoal bed, and downstream HEPA; these are not speci-fied in list on page 7.3-35.)

460.8, 460.9 OPEN ITEMS: Total system 24p not provided. No provision for indication and recording of system flow rate in control room.

460.10 Section 6.5.1.6, FSAR, references Section 6.5.3 for instrumenta-ti~ n and actuation requirements; correct reference is Section o

7.3.1.

C.

FHACES/FHAES Instrumentation provided for the FHACES includes (Ref.

Section 7.6.1.9b):

- Fan Status.

Status light in control room.

- Low Air Flow. Alarm in control room.

- Smoke. Alarm in control room

- High/ Low Alarm, Heating Coil Air. Alarm in control room.

- High Radiation, in Exhaust Duct. Alarm in control room.

- Charcoal Bed Temperature. Continuous indication on con-trol room panel high/high alarms.

- Moisture, Exhaust Air. High alarm in control room.

OPEN ITEMS:

Items not consistent with ANSI N509 and Regulatcry Guide 1.52:

460.11

- Unit outlet flow not shown to be indicated or recorded in control room.

460.12

- Component or system pressure drops (ap,2Ap) not indicated or recorded in control room.

460.13

- No status indication in control room of delug' ' valve position, e

valve / damper operator position.

- Section 6.5.1.5, FSAR, references Section 9.4.1 for instru-460.14 mentation and actuation requirements; correct reference is Section 7.6.1.9.

IV. FINDINGS Subject to resolution of the above open issues, our findings are as follows:

The ESF atmosphere cleanup systems include the equipment and instrumentation to control the release of radioactive materials in gaseous effluents following a postulated design basis acci-

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dant. The scope of our review included an evaluation of these systems with respect to the guidelines of Regulatory Guide 1.52.

We have reviewed the applicant's syctem descriptions and design criteria for the ESF atmosphere cleanup systems. The basis for t

acceptance in our review has been conformance of the applicant's designs, design criteria, and design bases for the ESF cleanup systems to applicable regulations, guides and industry stand-ards. Based on our evaluation, we find the proposd ESF atmosphere cleanup systems are acceptable, and the filter efficiencies given in Table 2 of Regulatory Guide 1.52 are appropriate for use in accident analyses.

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I 10.4.2 MAIN CONDENSER EVACUATION SYSTEM 10.4.2.1 System Description

. The main condenser evacuation system is designed to (1) establish a vacuum on the condenser during startup, (2) remove noncondensible gases from the main condenser and discharge them to the gaseous radwaste system, and (3) condense any steam removed from the con-denser with noncondensible gases and return the condensate to the condenser.

1 The major components are the mechanical vacuum pumps and the steam jet air ejectors. The main condenser evacuation system is designed to minimize the potential for explosion in the piping upstream of the catalytic recombiners in the offgas system by maintaining suf-ficient dilution steam in the steam jet air ejector discharge to, limit the hydrogen concentration to less than four percent by volume. The steam jet air ejectors, intercoolers, and the offgas system (Section 11 of this report) are designed to withstand an explosion in the offgas system. The hydrogen concentration at the outlet of the second stage air ejector will be maintained below four percent hydrogen in air by the addition of dilutien steam. On indication of low steam pressure or low steau flow, the operating steam jet air ejector will be removed from service and the standby air ejector activated. A hydrogen analyzer will be provided on the outlet of each recombiner to preclude the buildup of explosive mixtures.

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. 10.4.2.2 Evaluation Findings The Effluent Treatment Systems branch has verified that sufficient information has been provided and that the main condenser evacua-tion system design is adequate to support the following:

The main condenser evacuation system includes equipment and instru-ments to establish and maintain condenser vacuum and to prevent an uncontrolled release of radioactive materials to the environment.

The scope of our review included the system capability to transfer radioactive gases to the gaseous waste processing system or ventila-tion exhaust systems, the design provisions incorporated to monitor and control releases of radioactive materials in gaseous effluents in accordance with General Design Criteria 60 and 64 and the quality group classification of equipment and components used to collect gaseous radioactive wastes re17.tive to the guidelines of Regulatory Guide 1.26.

We have reviewed the applicant's system descriptions, piping and instrumentation diagrams, and design criteria for the components of the main condenser evacuation system. The basis for acceptance in our review has been conformance of the applicant's designs, design criteria, and design bases for the main condenser evacuation system to the applicable regulations, regulatory guides, 4

and industry standards referenced above. Based on our evaluation, we find the proposed main condenser evacuation system acceptable (including tydrogen control provisions).

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10.4.3 TURBINE GLAND SEALING SYSTEM 10.4.3.1 System Description The turbine gland sealing system is designed to provide a con-tinuous supply of " clean" steam to main turbine shaft seals, the stem packings of stop valves, control valves, combined intennediate valves and bypass valves, the shaft seals of the reactor feed pump turbines and the stem packing of the reactor feed pump turbines, and of stop and control valves. This sealing steam is used to prev :nt ;ir leaking into the steam cycle and radioactive steam Ai.q out of the steam cycle into the Turbine Building.

10.4.3.2 Evalus tion Findings Our review included the source of sealing system steam and the provisions incorporated to monitor and control releases of radio-active material in gaseous ef fluents in accordance with General Design Criteria 60 and 64, and Regulatory Guide 1.26.

The basis for acceptance in our review has been confonnance of the applicants' design, design criteria, and design bases for the turbine gland sealing system to the applicable regulations refere. iced above. Based on our evaluation, we find the design of the steam seal system to be acceptable.

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11.0 RADI0 ACTIVE WASTE MANAGEMENT I

'4 The review performed under this section pertains to the applicant's design provisions for controlling, processing, packaging, or minimizing radioactive plant effluents resulting from normal operation, and anticipated operational occurrences. Projected annual releases of liquid and gaseous radioactive effluents and projected i

volumes of solidified processed radioactive wastes calculated by the i

applicant are compared with data from operating plants having similar nuclear steam supply systems and comparable waste treatment systems.

The applicant's provisions for the instrumented monitoring and for the sampling and analysis of liquid and gaseous radioactive effluents are compared to guidelines of appropriate Regulatory Guides.

The radioactive waste management systems provided by the applicant

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are essentially as described in Section 11.0 of the Safety Evalua-tion Report for the construction permit stage (SER-CP) dated July 1974. The liquid radioactive waste systems process wastes from i3 equipment and floor Jrains, phase separator decantation, demineralizer backwash, demineralizer regenerants, decontamination and laboratory wastes, and laundry and shower wastes. The gaseous radioactive waste systems include a refrigerated charcoal delay system to allow decay of short-lived noble gases removed from the main condenser and treatment of building ventilation exhausts through high ef ficiency

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. p&rticulate air filters and charcoal adsorbers to reduce releases of radioactive materials to "as low as is reasonably achievable" levels in accordance with 10 CFR Part 20 and 10 CFR Part 50.34a. The solid

'i radioactive waste system provides for the volume reduction, solidi-fication, packaging, and storage of radioactive wastes generated during station operation prior to shipment offsite to a licensed facility for disposal.

The process and effluent radiological monitoring and sampling systems provided by the applicant for normal operation and anticipated 4

operational occurrences are essentially as described in Section 11.5 of tr.e Safety Evaluation Report for the construction permit stage (SER-CP), dated July 1974. These systems have been augmented by the addition of high range ef fluent sampling and monitoring systems '

to accommodate the maximum calculated releases which could occur as the result of an accident, in accordance with the guidance of NUREG-0737 and Regulatory Guide 1.97.(II AIEvaluation pending submittal of design data; licensee has committed to meeting provisions of Regulatory Guide 1.97 and NUREG-0737.

I 1 11.1 LIQUID RADI0 ACTIVE WASTE TREATMENT SYSTEMS The review performed under Standard Review Plan 11.2 pertains to the following system design factors.

System design System design objectives Design criteria Methods of treatment Expected releases Parameters used in calculating releases P& ids and flow diagrams Equipment system and component design capacities Expected system flows and radioactivity concentrations Expected component decontamination factors System holdup time (as applicable)

Availability of standby equipment Alternate processing routes System interconnections Quality group classification Special design provisions i

We review the liquid radwaste processing systems and components with respect to the above factors on an individual component basis, on the-basis of interaction between components comprising a system, and on interaction between systems. Our review must arrive at the conclusion that there is adequate assurance that a given system will perfora its design function under all postulated cambinations of nomal operating conditions while keeping discharges to the environment "as low as is reasonable achievable". Our review did not identify any open items.

We reviewed the applicant's source tem for 1iquid radioactive effluents, which was calculated using the methods described in NUREG-0016 (1976).

Based on the applicant's list of parameters employed in the calculation, 1

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< on comparison of the applicant's source tem with source tems previously calculated by the staff for similar plants employing similar liquid rad-waste treatment system components and design features, and on comparison with reported annual average releases from similar plants, we conclude that the applicant's source tem is representative of liquid radioactive effluents which can be expected to be released frm the Perry Nuclear Power Plant, Unit No.1; therefore, the staf f has adopted the applicant's source term for its use in detemining the environmental impact of liquid rel eases.

The applicant has employed components and system designs for his liquid radwaste treatment systems which are consistent with components and systems used in operating plants and which have demonstrated their ef ficiency ratings, capacity ratings, and availability factors in extensive operational use. The capacities of system components are consistent with the size of the plant and with the expected volumes of waste to be processed. Processing characteristics and radioactive decontamination ef ficiencies of the systems and components used have been demonstrated or verified in operational use.

Our findings are as follows:

The liquid radwaste treatment systems include the equipment and instru-mentation to control the release of radioactive materials in liquid ef flue nt s.

. ',. 7l i In our evaluation, we considered releases of radioactive materials in liquid effluents for nonnal operation including anticipated operational occurrences based on expected radwaste inputs over the life of the plant for each reactor on the Perry site. We detennined that the pro-posed liquid radwaste treatment systems will be capabic of maintaining releases of radioactive materials in liquid effluants such that the calculated individual doses in an unrestricted area from all pathways of exposure are less than 3 millirems to the total body and 10 millirems to any orgar..

We considered the capabilities of the proaosed liquid radwaste treatment system to meet the anticipated demands of the plant due to anticipated operational occurrences and have concluded that the system capacity and design flexibility are adequate to meet the anticipated needs of the i

plant.

We reviewed the applicant's quality assurance provisions for the liquid radwaste systems, the quality group classifications used for system components, and the seismic design applied to structures housing these system 3.

The design of the systems and structures housing these systems meet the criteria as set forth in Regulatory Guide 1.143.

i Pending detennination by RAB.

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We reviewed the provisions incorporated in the applicant's design to control the releases of radioactive materials in liquids due to inad-vertent tank overflows and concluded that the measures proposed by the applicant are consistent with the criteria as set forth in Regulatory j

Guide 1.143.

based on the foregoing evaluation, we conclude that the proposed liquid radwaste treatment sy: tem is acceptable. The basis for acceptance has beer, conformance of the applicant's design, design criteria, and design bases for the liquid radioactive waste treatment systems to the Commis-sion's regulations and to applicable Regulatory Guides, as referenced ab ov e.

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11.2 GASEOUS RADIOACTIVE WASTE TREATMENT SYSTEMS The review perfomed under Standard Review Plan 11.3 pertains to the following system design factors; System design l

System design objectives Design criteria Methods of treatment Expected releases Parameters used in calculating releases P& ids and flow disgrams Equipment system and component design capacities Expected system flows and radioactivity concentrations Expected component decontamination factors System holdup time (as applicable)

Availability of standby equipment Alternate processing routes System interconnections Quality group classification Special design provisions We review the gaseous radwaste and building ventilation exhaust treatment systems and components with respect to the above factors on an individual component basis, on the basis of interaction between components comprising a system, and on interaction between systems. Our review must arrive at the conclusion that there is adequate assurance that a given system will perfom its design function under all postulated combinations of nomal operating conditions, while keeping discharges to the environment "as low l

as is reasonably achievable". Our review identified one open item.

We reviewed the applicant's source tem for gaseous radioactive ef fluents which was calculated using the methods described in NUREG-0016 (1976).

Based on the applicant's list of parameters employed in the calculation,

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! on comparisol of the applicant's source term with source terms pre-viously calculated by the staff for similar plants employing similar gaseous radwaste and building ventilation exhaust treatment system components and design features, and on comparison with reported annual average releases from similar plants, we concluded that the applicant's source term is representative of gaseous radioactive effluents which can be expected to be released from the Perry Nuclear Power Plant, Unit No.1; therefore, the staf f has adopted the i

applicant's source term for its use in detennining the environmental impact of gaseous releases.

The applicant has employed components and system designs for his gaseous radwaste and building ventilation exhaust treatment systems which are consistent with components and systems used in operating I

plants and which have demonstrated their ef ficiency ratings, capacity ratings, and availability factors in extensive operational use.

The applicant states that the design of the refrigerated charcoal of fgas system meets the requirements of Regulatory Guide 1.143. For 1

combustible gas control, redundant hydrogen analyzers have been provided upstream of the delay beds and downstream of the recombiners. Process steam is used for dilution at all times and is sized to keep gases from the air ejector below the flammable limit. Pressure vessels in the system are designed to 350 psig static pressure and piping and valving are

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. designed to resist dynamic pressures encountered in long runs of piping at design temperature. The system is designed to operate at less than 2 psig (17 psia) during nomal operation and at a maximum of 7 psig (22 psia) during startup. During nomal operation, the design meets the SRP 11.3 criteria of 20 times the operating absolute pressure for systems designed to withstand the effects of a hydrogen explosion.

In addition to the ESF atmosphere cleanup systems described under Section 6.5.1 of this draft SER, the applicant has provided filtered I

ventilation exhaust treatment systems for the following facilities:

Controlled Access and Miscellaneous Equipment Areas HVAC System Offgas Building Exhaust System Radwaste Building Exhaust System l

Auxiliary Building Ventilation System Reactor Building Containment Vessel and Drywell Purge For each system, treatment provisions include, sequentially, roughing or prefilters, upstream HEPA filter, charcoal adsorber, and downstream HEPA filter. The applicant has not, however, specified his design cri-teria for these systems and has not provided information comparing his design to the guidelines of Regulatory Guide 1.140.

In Table 3.2.1 of the FSAR, the applicant shows the design classification to be seismic Category I and construction codes in accordance with ERDA 76-21, ANSI 509, RDT M16-IT, and ANSI N101.1. The FSAR does not contain

j specific information to determine conformance to R.G.1.140; however, if the design conforms to N509, applicant should have no deviations 460.15 from R.G. 1.140. OPEN ITEM: Applicant should provide information relative to conformance to R.G.1.140 guidelines.

The capacities of system components are consistent with the size of the plant and with the expected volumes of waste to be processed.

Processing characteristics, radioactive decontamination efficiencies, and holdup or decay times of the systems and components have been demonstrated or verified in operational use.

Subject to resolution of the one open item identified above, our findings are expected to be as follows:

The gaseous radwaste treatment system includes the equipment and instruments to control the release of radioactive materials in gaseous effluents.

In our evaluation, we considered releases of radioactive material (noble gases, radioiodine and particulates) in gaseous effluents for normal operation including anticipated operational occurrences based on expected radwaste inputs over the life of the plant for each reactor on the Perry site. We have determined that the proposed gaseous radwaste treatment systems are capable of maintaining releases of radioactive materials in gaseous ef fluents such that the calculated individual doses in an un-restricted area from all pathways of exposure are less than 5 mrem to

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) the total body and 15 mrem to any organ and that releases of radioiodine and radioactive material in particulate fom are less than 15 mrem to any organ.(4I We also considered the potential consequences resulting from reactor operation with a fission product release rate consistent with a noble gas release rate to the reactor coolant of 100 uCi/MWt-sec at 30 minutes decay determined that under these conditions, the concentrations of radioactive materials in gaseous effluents in unrestricted areas will be a small fraction of the limits in 10 CFR Part 20.(5)

We considered the capabilities of the proposed gaseous radwa'te treat-4 ment systems to meet the anticipated demands of the plant due to anticipated operational occurrences and have concluded that the system capacity and design flexibility are adequate to meet.the anticipated -

needs of the plant.

We reviewed the applicant's quality assurance provisions for the gaseous radwaste systems, the quality group classifications used for system components, the seismic design applied to the design of the system, and of structures housing the radwaste systems. The design of the system and structures housing these systems meet the criteria as set forth in Regulatory Guides 1.143 and 1.140.

"IPending determination by RAB.

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Pending detemination by RAB.

1 We reviewed the provisions incorporated in the applicant's design to control releases due to hydrogen explosions in the gaseous radwaste system and conclude that the measures proposed by the applicant are adequate to prevent the occurrence of an explosion or to withstand the effects of an explosion.

Based on the foregoing evaluation, we conclude that the proposed gaseous radwaste treatment system is acceptable. The basis for accept-ance has been conformance of the applicant's designs, design criteria, and design bases for the gase)us radwaste treatment system to the applicable regulations and Regulatory Guides referenced above.

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. 11.3 SOLID RADIOACTIVE WASTE MANAGEMENT SYSTEMS The review performed under Standard Review Plan 11.4 pertains to the following system design factors:

System design System design objectives (1) Expected and design volumes of waste (2) Activity and expected radionuclide distribution Equipment design capacities Parameters employed in design Piping and instrumentation diagrams and flow diagrams Expected chemical content, flows and radionuclide concentrations Expected volumes requiring re-processing or further treatment Methods for solidification, solidifying agent employed Process control program Type and size of solid waste containers Method of filling and handling containers Monitoring and decontamination Packaging and storage Quality group classification Special design provisions We reviewed the solid radioactive waste management systems and components with respect to the above factors on an individual component basis, r,n the basis of interaction between components comprising a system, and on interaction between systems. Our review must arrive at the conclusion that there is adequate assurance that a given system will perform its design function under all postulated combinations of nonnal operating conditions. Our review did not identify any open items.

We reviewed the applicant's estimates of solid radioactive waste volumes and the attendant estimates of radioactivity content. We compared the applicant's estimates of waste volume and content with the

3 staff's expected volumes and content for similar plants, which are based on average annual volumes and content reported by operating pl ants. We found no significant difference between the applicant's estimates and the staff's expected volumes and content; therefore, we have accepted the applicant's estimates for use in our evaluation of the solid radwaste systems.

The applicant has employed components, system designs, and design criteria for his solid radwaste systems which are consistent with com-ponents and systems used in operating plants and which have demonstrated their efficiency ratings, capacity ratings, and availability factors in extensive operational use. The applicant has selected a cement-silica solidification system for conversion of wet wastes to a solid material.

A compacting system will be used for volume reduction of dry solid wa'stes where practicable. 55-gallon steel drums will be employed for both solidification of wet wastes and packaging of dry wastes; however, larger containers can also be used and are compatible with the packaging systems, except that the large containers would not be used for compacted dry wastes.

460.16 It is noted that the applicant has not described a process control program for the purpose of providing assurance that solidification of wet wastes will meet the applicable requirements for packaging, handling, shipping, and disposal, nor has he canmitted to such a program. Whil e

. this is not a subject to be addressed in the SER, such a program will be a requirement of the Technical Specifications.

(Reference Branch Technical Position BTP-ETSB 11-3, attached to SRP 11.4.)

Applicant has provided a shielded storage vault of approximately 16,200 ft3 (usable space) for the on-site storage of solidified waste and a chielded volume of approximately 5,000 f t3 (usable space) for storage of compacted dry waste. The applicant projects an average 3

monthly generation rate of 8,100 ft per month of solidified wastes and 1,000 ft per month of compacted wastes. Assuming a 60% space utiliza-tion factor, the storage volumes would accommodate approximately a one-month generation of solidified waste and a 3-month generation of compacted waste. Since Branch Technical Position BTP-ETSB 11-3 provides for accomnodating at least 30-days generation of wastes, the applicant's -

provisions arc acceptable; however, in view of recent history in the availability of disposal sites, it is suggested that it would be prudent for the applicant to make contingency plans for additional on-site storage volume.

(Note: This latter statement is merely a suggestion, not an identified open item of the draf t SER.)

The applicant has committed to following appropriate federal and state regulations relative to the packaging and shipment of solid wastes to an approved of fsite burial facility.

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j Our findings are as follows:

"The solid waste system (SWS) includes the equipment and instrumentation used for the solidification, packaging, and storage of radioactive wastes prior to shipment offsitE for burial. The scope of the review of the SWS includes line diagrams of the system, piping and instrumentation diagrams (P& ids), and descriptive infomation for the SWS and for those auxiliary supporting systems that are essential to the operation of the SWS. The applicant's proposed design criteria and iesign bases for the SWS, and the applicant's analysis of those criteria and bases have been reviewed. The capability of the proposed system to process the types and volumes of wastes expected during normal operation and anticipated operational occurrences in accordance with General Design Criterion 60, provisions for the handling of wastes relative to the requirements of-

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10 CFR Parts 20 and 71 'and of app)lcable D0T regulations, and the applicant's qualitu group classification and seismic design relative to Regulatory Guide 1.143, have al so been reviewed. The basis for accept-ance in our review has been confomance of the applicant's designs, design criteria, and design bases for the solid radwaste system to the l

regulations and the guides referenced above, as. cell as to staff tech-nical positions and industry standards. Based on the foregoing evalua-i.1on, we conclude that the proposed solid radwaste system is acceptable."

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, r 11.4 PROCESS AND EFFLUENT RADIOLOGICAL MONITORING INSTRUMENTATION AND SAMPLING SYSTEMS The review perfonned under Standard Review Plan 11.5 pertains to the systems provided by the applicant for the purposes of detecting and measuring concentrations of racloactive materials within plant process systems and in plant gaseous and liquid ef fluents. Our review was concerned with the applicant's provisions for the instrumented monitor-ing of specific plant process streams and plant effluent release paths and for the sampling and laboratory analysis of materials in specific plant effluent release paths. Our review included:

the type, location, and range of instrumented monitoring; actuation of control or isolation devices by instrumented monitoring; location of sensors relative to J

process system piping or ducts and relative to effluent piping, ducts, diffuser:, stacks, or other release points; special provisions for sampling or monitoring, e.g., isokinetic sampling; provisions for laboratory analysis of collected samples; location of sampling points; provisions for monitoring releases from postulated accidents; descrip-tions or procedures for calibration, maintenance and inspection; and layout drawings, P& ids, and process flow diagrams showing sensor or instrument locations.

We reviewed the process and effluent radiological monitoring instru-mentation and sampling systems with respect to the factors listed above.

Our review must arrive at the ccnclusion that there is adequate assur-ance that a given monitor or -- in other cases -- provisions for

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. sampling and laboratory analysis, will be capable of providing the intended design function or purpose under all postulated conditions of nonnal operation, including anticipated operational occurrences, and that either adequate range cap 6 city or alternative high-range capability is provided for the detection and measurement of radioactivity levels in ef fluents during and following accidents.

460.17 With respect to the monitoring, sampling and analysis of process and effluent streams under accident conditions, the applicant has not as yet made his detailed submittal on items identified in Sections II.F.1-1 and II.F.1-2 of NUREG-0737; therefore, these must be identified as open items. (Note-Items in II.3.3 will be reviewed and reported elsewhere.)

No open items were identified with respect to monitoring, sampling, and analysis of process nr affluent systems for normal operations, including anticipated operational occurrences.

The applicant has employed sensors, sample collecting and conditioning systems, and sample analysis capability for his process and effluent radiological monitoring and sampling systems which are consistent with those employed in operating plants and which have demonstrated their of fectiveness ir extensive operational use. The applicant has pro-vided instrumented monitoring for effluent gaseous and liquid discharge paths in accordance with the guidelines of Regulatory Guide 1.21.

Similarly, the applicant has provided instrumented monitoring at many l

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. points in the in-plant liquid and gaseous radioactive process systems for the purposes of quantifying and controlling radioactivity concen-trations in plant systems in accordance with the guidance in Standard Review Plan 11.5.

Subject to resolution of the open items noted above for NUREG-0737

- items, our findings are expected to be as follows:

"The process and effluent radiological monitoring and sampling systems include the instrumentation for monitoring and sampling radioactively contaminated liquid, gaseous, and solid waste process and effluent streams. Our review included the provisions proposed to sample and monitor all station effluents in accordance with General Design Criterion 64, the provisions proposed to provide automatic termination of effluent releases and assure control over discharges in accordance with General Design Criterion 60, the provisions proposed for sampling and monitor ng plant waste process streams for process control in accordance with Ceneral Design Criterion 63, the provisions for conducting sampling and analytical programs in accordance with the guidelines in Regulatory Guide 1.21, and Regalatory Guide 4.15, and the provisions for sampling and monitoring process and effluent streams during postulated accidents in accordance with the guidelines in Regulatory Guide 1.97.

The review included piping and instrument diagrams and process flow diagrams for the liquid, gaseous, and solid

. radwaste systems, and for ventilation systems, and the location of monitoring points relative to effluent release points as shown on the site plot diagrams."

"The basis for acceptance in our review has been conformance of the applicant's designs, design criteria, and design bases for the process and effluent radiological monitoring, instrumentation and sampling systems to the applicable regulations and guides, as indicated above, as well as to staff technical positions and industry standards.

Based on our evaluation, we find the proposed systems to be acceptable."

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