ML20039B373
| ML20039B373 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/16/1981 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM FYR-81-160, NUDOCS 8112220594 | |
| Download: ML20039B373 (2) | |
Text
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YANKEE ATOMIC ELECTRIC COMPANY Q' l,hb\\
1671 Worcester Road, Framingham, Massachusetts 01701 2.C.2.1
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.YAuxse December 16, 1981 Ift /
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United States Nuclear Regulatory Commission g.
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Washington, D. C.
20555 Attention:
Office of Nuclear Reactor Regulation p/ t '..
Mr. Darrell G. Eisenhut, Director m
a a Division of Licensing D.
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References:
(a) License No. DPR-3 (Docket No. 50-29)
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(b) USNRC Letter to YAEC, dated July 27, 1981
Subject:
NUREC-0737, Item II.B.3, Post-Accident Sampling Capability
Dear Sir:
We have reviewed the apparent NRC basis for the required short term post-accident chloride sampling and analysis. We are not convinced that the value of compulsory sampling and analysis at our facility would be worth the personnel exposure required to perform those tasks.
Although the staff has indicated that this sampling and analysis may be accomplished using automated techniques, the availability and reliability of the necessary equipment forces us to conclude that reliable, qualified, automatic equipment is not available.
Throughout the combined operating history of the plants in the Yankee organization, no situation has been encountered in which significant chloride l
intrusion into the primary coolant system has occurred. During almost forty j
reactor years of operation, no mechanism has been identified by which significant chloride contamination could occur without the presence of serious system failures which, in themselves, would result in appropriate operator action to correct the problem.
It is not possible for significant chloride contamination of the reactor coolant system to take place in the absence of multiple system failures which could not be overlooked by an operator, even in a post-accident scenario. Our determination is based on the following facts:
1)
Technical Specifications define both chloride and conductivity limits, for reactor cooling water. To meet these requirements, it is necessary to maintain all reactor make up water, including the large volumes reserved for ECCS systems use, below the Technical
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OYb Specificaticn limit.
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U. S. Nuclear Regulatory Commission December 16, 1981 Page 2 2)
After the postulated accident begins, it is this chloride-free water that will be used to keep the core covered and cool down the plant, thus eliminating chlorides while the system is at elevated temperature and pressure, the principle conditions necessary for chloride stress corrosion cracking.
3)
Sherman Pond, if ever used as a source of make up water, contains approximately 2-3 ppm chloride and is essentially pure water.
4)
The probable source of chloride contamination at TMI, large amounts of chloride contaminated sodium hydroxide, does not exist at Yankee.
For the reasons discussed above, we cannot responsibly commit to compulsory post-accident sampling and analysis for chlorides. We are convinced that our position, which provides the option to utilize the capabilities inherent in the current sampling system, is more appropriate.
With our present system design, we will be able to obtain a sample of primary coolant and perform a chloride analysis on that sample within four days af ter an accident occurs if we deem such action to be appropriate. This capability will only be utilized following a management decision that exposure associated with such a sample is warranted based on the accident conditions.
Yankee believes that this position satisfies the intent of NUREC-0737, Item II.B.3 as it applies to our facility. Should you have further questions regarding this information, please contact us.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY NYY L. H. Heider Vice President
,