ML20039C077
| ML20039C077 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/18/1981 |
| 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 8112280382 | |
| Download: ML20039C077 (12) | |
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December 18, 1981 EF2 - 55,569, Revision 1 Mr. Darrell G.
Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr. Eisenhut:
Reference:
Enrico Fermi Atomic Power Plant, Unit 2 NRC Docket No. 50-341
Subject:
Post Accident Sampling Licensing Conditions Response Enclosed are the revised responses on the Enrico Fermi 2 post accident sampling system.
These responses further address the licensing conditions stipulated in the SER with the exception of an interim procedure for relating radionuclide concentrations to fuel damage which will be submitted 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.
Sincerely,
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Enclosure cc:
L. L. Kintner B. Little 8112280392j Q Qt PDR ADOCK PDR A
Attachment to:
EF2 - 55,569, Revision 1 December 18, 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 with 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, Revision 1 December 18, 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 / Total Gas pH
Boron 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
Attachment to:
EF2 - 55,569, Revision 1 December 18, 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 wFich there is core degradation, assuming loss of off-site pow c.
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.
l
Attachment to:
EF2 - 55,569, Revision 1 December 18, 1981 4.
Provide a procedure for relating radionuclide gaseous and 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 and a detailed procedure status and schedule for submittal of the refined procedure will be provided for review prior to May 1, 1982.
Attachment to:
EF2 - 55,569, Revision 1 December 18, 1981 5
Provide a method for verifying that reactor coolant dissolved oxygen is (0.1 ppt if reactor coolant chlorides are deter-mined to be >0.15 ppm.
EDISON POSITION:
If reactor cools.nt chlorides are determined to be >0.15 ppm verification that dissolved oxygen is (0.1 ppm will be accomplished oy 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, Revision 1 December 18, 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 System (PASS) is tested on a semi-annual basis to insure operability and provide opera-tor training as required.
Specific PASS proceduras 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 reluired to show proficiency in PASS operation and in chemical analysis) on a semi-annual basis.
Attachment to:-
EF2 - 55,569, Revision 1 December 18, 1981 7
Demonstrate that the reactor coolant system and suppression chamber sample locations are representative of core conditions.
EDISON POSITION:
Reactor coolant samples are obtained from two 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, 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 water level can be maintained at or near normal water level after the accident.
2.
Reactor power. level is greater than 1% rated, up to approximately 10% rated, when the~ water sample is taken.
3 1
l Regarding condition A, after a small break or non-break acci-j 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 then 10% rate'd recirculation flow due.to natural circulation.
This amount of core flow assures the 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-l 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 i
dilution would occur; the bulk of the water going through the l~
jet. pump.comes from the reactor core.
t
. 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 line is also nonnected 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.
Direction to perform this operation is described in Post Accident Sampling Procedure 78.000.14.
Similarly, a suppression pool liquid sample is obtained from the RHR loop lined up in the suppression cooling mode.
The representativeness of the suppression pool sample is assured by the following:
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 of 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 or safety / relief valve discharge sparger.
The estimation of core damage procedure will indicate specifi-cally which samples are to be acquired, based on accident conditions.
For example, if it is determined that the acci-dent is a small break and decay power is greater than 1%, the estimation of core damage procedure will state that samples will be acquired from the jet pump sample point.
Attachment to:
EF2 - 55,569, Revision 1 December 18, 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 Accident 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 on 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-Carminic Method The Hach method closely follows the ASTM D3082-74, " Standard Test Method of 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 coolant 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 samples (0.1 to 10 ml) provided 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:
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 OS/cm.
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.... 5 Radiochemical Analysis Isotopic analysis of post-accident 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 calibration curves for liquids and gases as well as for particulate filters and iodine cartridges will be readily available and regularly updated.
A high resolution germanium detector coupled to a multichannel analyzer with computer data reduction will handle the acquired samples.
6.
Gas Analysis-Gas Chromatography 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 fraction of dissolved gases a
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-g gen and nitrogen stripped from the coolant will be signifi-l 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.
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