ML20032D996
| ML20032D996 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/13/1981 |
| From: | Tauber H DETROIT EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM EF2-55-569, NUDOCS 8111190475 | |
| Download: ML20032D996 (12) | |
Text
Harry Tcuber V.cc Pres +rs Pg wr ng and Corwuct on r
Detroit 2000 Second Avenu Ecison wwe November 13, 1981
. GJ$ %
,5 b -)
EF2 - 55,569 W}.~
g J >I$
[4 NOV1819815 :
Mr. Darrell G.
Eisenhut, Director 9
Division of Licensing u.s.nc5Nl((T# h--
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 5,
Washington, D.
C.
20555 g,
Dear Mr. Eisenhut:
Reference:
Enrico Fermi Atomic Power Plant, Unit 2 NRC Docket No. 50-341 Subj ect :
Post Accident Sampling Licensing Conditions Response Enclosed are the required responses for the Enrico Fermi 2 post accident sampling system.
These responses address the licensing conditions stipulated in the SER with the exception of an interim procedure for relating radio-nuclide concentrations to fuel damage which will be sub-mitted prior to May 1, 1982.
We will continue to work with General Electric and EPRI to establish a more detailed procedure for the estimation of core damage.
We look forward to receiving a favorable finding on this transmittal.
Sincerely, encl.
cc:
L.
L. Kintner B.
Little 1j a s
L 8111190475 811113 DR ADOC,K 05000341 PDR.
Attachment to:
EF2 - 55,569 November 13, 1981 1.
Demonstrate compliance with all requirements of NUREG-0737, II.B.3, for sampling, chemical and radionuclide analysis capabi-lity, under accident conditions, including sampling and analy-sis of chloride and borate in the reactor coolant.
(Borate analysis results should be available within two hours of ini-tiating borate injection into the reactor).
EDISON POSITION:
Compliance with the requirement of NUREG-0737 II.B.3 for sampling, chemical, and radionuclide analysis capability under accident conditions is described in Appendix H.II.B.3 of Amendment 36 in the EF2 FSAR.
Chloride and boron sampling and analysis of undiluted reactor coolant will be performed as follows:
1.
Chloride analysis will be performed on the undiluted reac-tor coolant sample acquired by the Post Accident Sampling System (PASS).
This analysis will be performed in an off-site facility witt analytical results available within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the time a decision is made to take a sample.
2.
Boron analysis will be performed on the reactor coolant sample acquired by the PASS if boron injection is ini-tiated.
This analysis will be performed on-site and also off-site for confirmatory purposes.
In accordance with NUREG-0737, II.B.3, boron sampling and analysis will be performed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the time a decision is made to take a sample.
Attachment to:
EF2 - 55,569 November 13, 1981 2.
Commit to meet the sampling and analysis requirements of Reg.
Guide 1 97, Rev. 2, including sampling and analysis for pH and dissolved oxygen in reactor coolant.
EDISON POSITION:
The following post accident analyses will be performed on samples gcquired from primary coolant and containment air within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the time a decision is made to sample:
PRIMARY COOLANT Gross Activity Gamma Spectrum Dissolved Hydrogen /Tntal Gas Dissolved Oxygen gHBoron analysis will be performed if boron injection is initiated.
" Chloride analysis will be performed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the time a decision is made to sample.
CONTAINMENT AIR Hydrogen Oxygen Gamma Spectrum m__*,.-
m..
a -
u
Attachment to:
EF2 - 55,569 November 13, 1981 3
Verify that all electrically powered components associated with post accident sampling are capable of being supplied with power and operated within 30 minutes of an accident in which there is core degradation, assuming loss of off-site power.
EDISON POSITION:
The post accident sampling system isolation valves and sampling panel are supplied with assured Class IE power and automatically restorable power, respectively. Both can be operated within 30 minutes of an accident in which there is a loss of off-site power.
4 Attachment to:
EF2 - 55,569 November 13, 1981 1
4.
Provide a procedure for relatitg radionuclide gaseous and; l
ionic species to estimated core damage, EDISON POSITION:
The nuclear industry is currently attempting to establish a technique for relating radionuclide gaseous and ionic species for the estimation of core damage.
General Electric and EPRI are currently pursuing the' development of such a procedure.
Until an acceptable and refined procedure _is developed, Detroit Edison will provide an interim procedure for the estimation of core damage.
The interim procedure-will be sub-
+
mitted for review prior to May 1, 1982.
k I
1 1
i I
f 1
4 k
i-
Attachment to:
EF2 - 55,569 November 13, 1981 5
Provide a method for verifying that reactor coolant dissolved oxygen is (0.1 ppm if reactor coolant chlorides are deter-mined to be >0.15 ppm.
EDISON POSITION:
If reactor coolant chlorides are determined to be >0.15 ppm, verification that dissolved oxygen is (0.1 ppm will be accomplished by determination of a positive hydrogen residual (5-10cc/kg).
When ALARA considerations permit, dissolved oxy-gen will be measured directly.
Attachment'to: -
EF2 - 55,569 November 13, 1981 6.
Provide information on (a) testing' frequency and' type of
. testing to ensure long-term operability'of the post accident sampling system, and (b) operator training requirements for post accident-sampling.
EDISON POSITION:
a.
The Post Accident Sampling Syste'. (PASS) is tested on a semi-annual basis to insure operability and provide opera-tor training as required.
Specific PASS procedures include procurement, transportation, and analytical requirements.
Analytical instrumentation is calibrated using approved Radchem procedures.
b.
Operation.of the PASS is included in.the formal training
. program for chemical technicians.
Chemistry supervisors as well as the chemical technicians will be, required to show proficiency in-PASS operation and in chemical analysis.
Attachment to:
i EF2 - 55,569 November. 13, 1981 2
7 Demonstrate that the reactor coolant system and suppression chamber sample locations are representatisa of-core conditions.
EDISON POSITION:
Beactor coolant samples are'obtained from.cwo points (jet pumps 5 and 15) in the jet pump pressure instrument system when the_ reactor is at pressure.
The jet pump pressure system has been determined to be an optimum sample point for accident
. conditions.
In order to assure that these provide a representative sample, 4
i two conditions should exist:
A.
Enough core flow to allow circulation of water from inside the shroud to the jet pump intake.
B.
No significant dilution by makeup water.
Two assumptions were made for this study:
1.
Reactor wat.er level can be maintained at or near normal water leve' after the accident.
2.
Reactor. power level is greater than 1% rated, up to approximately 10% rated, when the water sample is taken.
~
Regarding condition A, after a small break or non-break'acci-dent, the reactor water level will be maintained at or near normal water level by.the operator using Emergency Procedures.-
For decay power above 1% of rated power the core flow is esti-mated to be greater than 10% rated recirculation flow due to i
natural _ circulation.
This amount of core flow assures the j
existence of a flow route from the core to the sampling points; it takes about 3 to 4 minutes to circulate the entire reactor water inventory through the jet pumps. Therefore, a representative sample of the core water will be available at the~ jet pumps.
Regarding condition B, for small steam line breaks or non-break accidents, makeup water is pumped in to remove decay heat and to-make up for steam loss through the break. This makeup water amounts to approximately 2% of the core flow pre-sent.
Even for small liquid line breaks, the makeup water flow rate is -estimated to be less than 18% of the core flow present.
Therefore, it can be concluded that no significant dilution would occur; the bulk of the water going through the Jet pump comes from the reactor core.
4 i
. =.
t ;
1 In conclusion, the' jet pump discharge can supply a represen-tative sample of-the reactor core water for the PASS under conditions of small break or non-break accidents.
A single sample 111ne is also connected to both loops in the-Residual Heat Removal (RHR) system. This provides a means of obtaining a reactor coolant sample when the reactor is depressurized-and at least one of the RHR loops is separated in the shutdown cooling mode.
To assure'that the sample is.
representative under these conditions, samples will be acquired after the reactor water level has been raised-(approximately 18 inches) to the point where' water flows from the steam separators.
-Similarly, a suppression pool liquid sample is obtained.from the RHR loop lined up in the suppression cooling mode.
The representativeness of the supar:ssion pool sample is assured -
by the following:
4 1.
No safety relief valves discharge directly into RHR suction.
2.
The selected RHR loop.will be recirculated approximately 30 minutes prior to taking a sample.
3 Sample lines are installed on the discharge side of the RHR pumps, downstream # the pump check valves.
Suppression pool atmospheric samples are taken from taps on opposite sides of the pool proper. Each tap location is selected to maximize the distance to either a downcomer er safety / relief valve discharge sparger.
1 l
f P
1
. ~
Attachment to:
EF2 - 55,569 November 13, 1981 NRC STATEMENT In addition to the above licensing conditions the Staff is con-ducting a generic review of accuracy and sensitivity for analyti-cal procedures and on-line instrumentation to be used for post accident analysis.
We will require that the applicant submit data supporting the applicability of each selected analytical chemistry procedure or on-line instrument along with documentation demonstrating compliance with the licensing conditions four months prior to exceeding 5% power operation but review and approval of these procedures will not be a condition for full power operation.
In the event our generic review determines a specific procedure is unacceptable we will require the applicant to make modifications as determined by our generic review.
EDISON RESPONSE APPLICABILITY OF ANALYTICAL CHEMISTRY PROCEDURES AND ON-LINE INSTRUMENTATION FOR POST ACCIDENT SAMPLING The analytical chemistry procedures and on-line instrumentation for the Post Accidert Sampling System (PASS) were selected for:
1.
Operational support, 2.
Minimization of personnel exposure and contamination hazards, 3
Minimization of extensive dependence upon outside laboratories for analytical and long range operational support.
Tests conducted by General Electric" have assessed the effects of high fission product levels o:. conductivity, pH, boron, and chloride analyses.
Sampling and dilution techniques for liquids and gases have been selected to provide minimum operator exposure and adequate analytical detectabilty.
Procedures selected to meet PASS analytical requirements are described below:
- Irradiation Effect on Analytical Procedures, H. L. Kenitler, C. R. Judd
. 1.
Boron Analysis-Charminic Method
.The Hach method closely follows the ASTM D3082-74, " Standard Test Method cf Boron.in Water, Method A-Carminic' Acid Colorimetric Method."
The reagents and standards. utilized in this procedure are available-in.small quantitites.and con-veniently packaged and can.be quickly prepared.
Complete ana-lysis, including reagent preparation,-can be performed in-less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Analytical range for boron via this method is 0.1 to 10 ppm boron.
This directly corresponds to a range of 100 to 1000 ppm boron in undiluted coolar,t prior to the sample stations 0.1 to 10 ml dilution.
2.
Chloride Analysis Chloride analysis will be performed by an off-site analytical laboratory using approved procedures traceable to the National Bureau of Standards.- Diluted eamples (0.1 to 10 ml) provided i
by the PASS will be below the chloride.detectability limit and will not provide chloride quantification of 0.15 ppm which initiates required verification of dissolved oxygen.
Chloride analytical results will be'available within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the time a decision is made to obtain a sample.
3 pH pH will be determined by either of the following methods:
L A.
The pH paper is placed into a sample bottle and several, approximately 0.1 ml of liquid sample, is introduced using an air filled syringe.
pH paper range is 1-11 units and can distinguish differences of 0.25 pH units.
B.
At low conductivities (within technical specification), pH will be determined from the pH and conductivity curve (Figure 1).
Accurate pH measurements are difficult to make in very low conductivity water as the impedance of the solution may be significant as compared to that of the measuring device.
Consequently, conductivity measurements are usually considered a better indicator of the maximum H+ or OH concentration.
4.
Conductivity The PASS is equipped with a 0.1 cm ~1 conductivity cell.
The conductivity meter has a linear scale with a six position range selector switch to give conductivity ranges of 0-3, 0-10, 0-20, 1-100, 0-300, and 1-1000 MS/cm.
. 5 Radiochemical Analysis Isotopic analysis of post-accicent samples will follow normal counting room procedures.
Gas samples will be counted in standard off-gas sample vials and liquid samples will be counted in standard sample bottles.
Previously established geometries and calibratien curves for liquids and gases as well as for particulate filters and iodine cartridges will be readily available and regularly up2ated.
A high resolution germanium detector coupled to a multichannel analyzer with computer data reduction will handle the acquired samples.
6.
Gas Analysis-Gas Chromatograpny The gas chromatagraph is used to measure hydrogen, oxygen, and nitrogen in sample vials containing undiluted containment atmosphere samples and samples of dissolved gases stripped from the primary coolant.
Krypton is added as a spike for the purpose of determining the faction of the dissolved gases recovered in the sampling process. Calibration curves for the instrument will be prepared and periodically updated.
Although complete evacuation of the sample vials cannot be accomplished, it is expected that the amount of dissolved oxy-gen and nitrogen striped from the coolant will be signifi-cantly larger than that left in the evacuated vial and corrections can be made, if required, based on pressure measurements taken before and after the sampling process.
-