ML20039F937
| ML20039F937 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/07/1981 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8201140183 | |
| Download: ML20039F937 (60) | |
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co fir. Louis 0. De10eorge TMurley oThe reporting and/or Director of Nuclear Licensing RMattson recordkeeping requirments Comnom4ealth Edison Company RHartfield, MPA contained in this letter Post Office Box 767 SHanauer affect fewer than ten Chicago, Illinois 60690 OELD respondent; therefore, OMB 0IE (3) clearance is not required
Dear fir. DelGeorge:
under P.L.96-511."
Sthject: Byron SER Open Itens As you are aware, the HRC staff is currently involved in the safety review of the Byron Station and is planning to issue the SER in February 1932.
In the course of the safety review, several review branches have deternined that there exist areas in which insufficient infornation has been sublitted or that further questions have arisen in specific areas. flany of these questions have been forwarded to you in separate correspondence or have been discussed in neetings with the staff.
Enclosed are several sunnaries of ooen items provided by NRC branches which have been developed during our safety review.
(See Enclosures 1 - 8). You are requested to examine the enclosed suTiaries of open itens to ensure that the issues and resolutions are clear and to respond with a schedule for all items that you cannot answer before December 18, 1981.
Additionally, Enclosure 9 represents a draft SER input which has been provided by the Effuent Treatment Systems Branch (ETSB). You are requested to review that material and respond with information to resolve open itens in that area.
If you have any questions reqarding this reouest, or desire additional meetings to resolve the attached issues, please contact the Byron Project flanager, Stephen Chesnut.
Sincerely.
Original signed by8 B. J. Youngblood B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing
Enclosures:
- 1. PSB Electrical
- 6. CIIES Issues
- 2. AES Position
- 7. QAB Issues
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- 3. D M issues
- 8. PTR4 issons n
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Mr. Louis 0. DelGeorge-Director of Nuclear Licensing Commonwealth Edison Company 1
Post Office Box 767 Chicago, Illinois 60690 ces:
Mr. William Kortier U. S. Nuclear Regulatory Commission Atomic Power Distribution Resident Inspectors Office Westinghouse Electric Corporation 4448 German Church Road
.P. O. Box 355 Byron, Illinois 61010 Pittsburgh, Pennsylvania 15230 Ms. Diane Chavez Paul M. Murphy, Esq.
602 Oak Street, Apt. f4 Isham, Lincoln & Beale Rockford, Illinois 61108 One First National Plaza 42nd Floor Chicago, Illinois' 60603 Mrs. Phillip B. Johnson
-1907 Stratford Lane Rockford, Illinois 61107 Ms. Bridget Little Rorem Appleseed Coordinator 117 North L'inden Street Essex, Illinois 60935 Dr. Bruce von Zellin Department of Biological Sciences Northern Illinois University DcKalb, Illinois 61107 Mr. Edward R. Crass Nuclear Safeguards and Licensing Division Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 i
Nuclear Regulatory Commission
, Region III 1
Office of Inspection and Enforcement 799 Roosevelt Road Glen Ellyn, Illinois 60137 Myron Cherry, Esq.
Cherry, Flynn and Kanter 1 IBM Plaza, Suite 4501 Chicago, Illinois 60611 O
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Byron Station Power System Branch Electric Power Systems Section Open Itens a
1.
Information to complete review iaw BTP PSB-1 on adequacy of station electric distribution system.
2.
a.
thed for second level of voltage protection for each bus, b.
information on load shedding schene on the 4160-480-volt ESF transformer.
c.
Voltage analysts used to select transformer tap seetings d.
voltage level measurement of safety related buses from 4KV level to 120 volt level e.
ESF bus UV protection additional information 2.
Non Safety loads on Class IE ESF buses - isolation between non-safety loads and ESF sources 3.
DC monitoring and annunciation - addition of battery current, charger output voltage, and charger output current monitors in the control room 4.
DC control for primary and backup protection of RCP electrical penetrations.
5.
Power lockout to MOVs in Tech. Specs.
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AEB v 4 1T10N ON THE; CONTAINMENT SPRAY SYSTEM FOR
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s, The staff' finds that some astec'ts of'the. Byron-1 containment spray system are L
unacceptable with re~spect'to fission product removal. Standard Review Plan.
6.'5.[ states,"Inallcase's'theoperatinir.eriodofthecontainmentspray L_
system should not.be less'than tws hours" (Paoa 6'.5.2-3).
The Byron-1 FSAR and clarifying responses of the applicant indicate that there is no provislun.
for continuous operation of the spray system for two hours. 'We will require
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that _this provision be made, either by automatic switchover of the containment spray pumps from the injection ' mode,(reactor water storage tank (RWST) suction)
..y to the recirculation mode (suction from the containment sump), or by manual 7
_switchover.
If manual switchover is used, the staff must be assured that there will be sufficient time for operator assessment and actions i.o accomplish this switchover. The staff endorsessthe criteria in the proposed ANS 58.8, Rev. 2,
" Time Respon'se Design Crite'ria For Safety-Related Operatcr Actions," for judging whether or not'the time for operat6r actions is sufficient to justify manual v
switchover.
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The staff interprets the time responsa criteri' with respect to Byron-1 dit[pnIV.eientsis containment spray (CS) as foll,ows: ' Time Tes
.,, ' c or satisfied, because there will to at.least 20 minuites, between the design basis
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event alarm (CS initiation, in'this cu e) and the first time.for which operator
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3 arm in the RWST)7 However, Time Test action need be_. considered (lowi h 1evel 1
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w 2 may not be' satisfied,"because it require; that 5 + nx 1 m'inutes be assumed for y x completion c.f the ope'rator actiory.after initiation.of operator action (assumed to
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be when'the RWST-low-lo tlevel, alarms), where'"n" is the number of discrete manipulations required of the 6perator. 'Therii are four manipulations required L.
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Therefore, the criteria indicate that as much as ni,ne minutes Er could elapse between the low-low level and the time when switchover of the CS system to the recirculation mode could be accomplished. With both CS pumps
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operating, it appears that'the,RWST could be empty before this time, and thus is i
there is no assurance that the operation of the containment spray would be 1
continuous for two hours.
The applicant should either provide for automatic switchover to recirculation n.ade. or provide evidence that manual switchover can be acco'mplished within the a
time set by the proposed ANS 58.8 criteria.
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4 Byron Station Radiological Assessment Branch (RAB)
Additional Information Request The appliant should provide the following additional information to completely close open items in the SER.
1.
Byron's current organization structure should be modified to show that the Rad / Chem Supervisor has access to tne Station Superientendent for all radiation safety matters.
2.
Byron's radiation protection section should be separate from its chemistry section or the applicant should provide an alternative proposal to assure adequate technical direction of the radiation protection group and to assure that the rad / chem technicians naintain adequate qualifications in both technical specialties.
3.
Section 12.3 of the Byron FSAR should be revised to provide the adaitional information requested in Question 331.33 concerning airborne radioactivity monitors sensitivity.
4.
In order to complete our review of Item Ill.D.3.3 of NUREG-0737, the applicant should provide the following information:
1.
The number and type of samplers 2.
Sample flushing methods 3.
Sample analysis equipment, type, and location.
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Byron Station Core Performance Branch.
Additional Information Request I.
Thermal-Hydraulic Section 1.
supply the necessary information needed to complete our review of the Improved Thermal Design Procedure as applied to Byron /Braidwood; 2.
supply correct and consistent values of the minimum DNBRs for nominal conditions and the design transient; 3.
supply the generic or plant-specific margins which will be used to offset the DNBR reduction due to rod bow; and 4.
supply the information required by Item II.F.2, " Instrumentation for the Detection of Inadequate Core Cooling," of NUREG-0737,
" Clarification of the TMI Action Plan Requirements."
II. Fuel Section The applicant should provide the following plant-specific information which was not supplied in WCAP-9500:
1.
Confirmation that the predicted cladding collapse time exceeds the expected lifetime of the fuel.
p 2.
Supplemental ECCS calculations using NRC-supplied LOCA cladding models.
3.
A determination that the appropriate seismic-and-LOCA forces are bounded by the cases considered in WCAP-9401.
4.
A description of plans for on-line fuel system monitoring.
5.
A description of plans for post-irradiation poolside surviellance of fuel.
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SUMMARY
OF STATUS Alt 0' SCOPE OF REVIEW p
BYRON NUCLEAR PLANT UNITS 1 AND 2 Section 3.3.1 Wind Loadings Review is complete, no open items exist.
Section 3.3.2 Tornado Loadings Review is complete, no open items exist.
Section 3.4.2 WaterLehel(Flood)DesignProcedures Rahiewiscomplete,noopenitemsexist.
Section 3.5.3 Barrier Design Procedures
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Completionofrehiewpendingreceipt,rehiewandstaffacceptanceof additional information pertaining to protection of Category I manho.les -
against tornado missiles.
Section 3.7.1 Seismic Input Completion of review is pending on the resolution of the following items:
a)
Review and staff acceptance of structural reevaluation of Byron plant based on comparison with Marble Hill plant.
b)
Receipt, review and acceptance of seismic reanalysis of Byron river screen house using envelope response spectra obtained by finite element method and elastic half space.
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\\l Section 3.7.2 Seismic System Analysis and Section 3.7.3 Seismic Subsystem Analysis Completionofrehiewispendingresolutionofthefollowingitems:
a)
Rehiewandacceptanceofaaplicant'spositiononaccidental
- torsion, b)
Resolution of the applicant's position that the cable tray and support system is qualified for SSE only.
c)
Rehiewandacceptanceofdeterminationofnumberofmassssinthe_,
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containment and containment internal structures, d)
Rehiewandacceptanceofcriteriafordecouplingofsteamgenerator upper lateral support and the RPV.
Section 3.7.4 Seismic Instrumentation Procram Review is complete, no open items exist.
Section 3.8.1 Concrete Containment Completionofrehiewispendingonresolutionofthefollowingitems:
a)
Rehiew and acceptance of additional information on treatment of transient loads.
b)
Resolutionofthetendonssurheillanceplanproposedbytheapplicant c)
EYaluationoftheFSARcriteriafortangentialshearagainstASME/
A d)
Assessment of pendulum effect on containment crane.
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Section 3.8.3 Concrete and Structural Steel Internal Structures Review is complete, no open items exist.
Section 3.8.4 Other Category I Structures Completion of review is subject to the resolution of'the following items:
a)
Clarification of applicant's criteria contained in the FSAR with respect to Regulatory Guide 1.142.
b)
Review and acceptance of the criteria regarding design, quality
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control and quality assurance of turbine building mat, which is housing the essential service water system piping.
I c)
Assessment of structural integrity of safety related masonry walls.
d)
Evaluation of spent fuel pool racks asper criteria contained in the SRP.
The applicant indicated that the additional information pertaining to these items will be submitted in two stages, namely in November and December 1981, so that they can be resolved before the due date of the final SER which is January 7, 1981.
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o Byron Station Chemical Engineering Branch Additional Information Request Chemical Technology Section/ Corrosion Engineering Section 1.
Demostrate compliance with all requirements of NUREG-0737, 11.6.3, for sampling, chemical and radionuclide analysis capability, under accident conditions.
2.
Provide sufficient shielding to meet the requirements of GDC-19, assuming reg. Guide 1.4 source terms.
3.
Commit to meet the sampling and analysis requirements of Reg. Guide 1.97, Rev. 2.
4.
Verify that all electrically powered components associated with post accident sampling are capable of being supplied with power and operated, within thirty minutes of an accident in which there is core degradation, assuming loss of off site power.
5.
Verify that valves which are not accessible for repair after an accident are environmentally qualified for the conditions on which they must operate.
6.
Provide a procedure for relating radionuclide gaseous and ionic species to estimated core damage.
7.
State the design or operational provisions to prevent high pressure carrier gas from entering the reactor coolant system from on line gas analysis equipment, if it is used.
8.
Provide a method for verifying that reactor coolant dissolved oxygen is at 0.1 ppm if reactor coolant chlorides are determined to be 0.15 ppm.
9.
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.
- 10. Provide additional information on the condensate cleanup system.
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7 Byron Station Quality Assurance Branch Outstanding Issues 1.
The applicant has not responded to our question 421.19 concerning the devcatives from Regulatory Guide 1.94.
i 2.
The applicant has not responded to our question 421.22 concerning the list of items controlled under 10 CFR 50 Appendix B quality assurance program.
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o Byron Station Procedures ari Test Review Branch
-Procedures Section Section 13.5.2 I
1.
Commitment in Section 13.5 of FSAR to meet the regulatory positions of Regulatory Guide 1.33 Rev. 2.
March 1978 and ANSI 18.7 - 1976/ANS 3.2.
2.
Emergency Operating Procedures.
a.
Pilot monitoring review of section emergency operating procedures in accordance with I.C.8 of NUREG-0737.
b.
Commitment for review of emergency operations procedures by NSSS vendor.
3.
Development and review of anticipated transient without scram ( ATWS) procedures.
4.
I.C.I - Renasysis of accident and treaments will be reveiwed upon receipt of owners group submittal.
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6.5.1 Engineered Safety Feature (ESF) Atmospheric Cleanup System 6.5.1.1 Summary Description The engineered safety feature (ESF) atmospheric cleanup systems at Byron consist of process equipment and instrumentation necessary to control the release of radioactive iodine and particulate material following a design basis accident (DB A). At the Byron station, there are three filtration systems designed for this purpose. These systems are:
(1)
Control Room HVAC Makeup Air Filter Units (2)
Non-Accessible Area Exhaust Filter Plenum in the Auxiliary Building (3)
Fuel Handling Building Exhaust System The control room HVAC makeup air filter units are used to filter makeup air to the control room on either a high radiation signal from the radiation monitors in the outside air intake duct or upon activation by the control room operator. The source of the makeup air may be either the outside or the turbine building.
The non-accessible area exhaust filter plenums of the auxiliary building treat exhaust air from the non-accessible areas of the auxiliary building and discharge into the auxiliary building exhaust plenum upon receipt of a high radiation signal from the exhaust air duct or by manual initiation from the control room.
This system filters air from such areas as the floor drain and i
equipment drain sump rooms, RHR, containment spray, safety injec-l tion, positive displacement charging, and centrifugal charging l
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. 6.5.1.1 pump rooms, RHR heat exchanger rooms, radwaste and recycle evaporator rooms along with various other sunp rooms, pump rocms, aisles and tunnels and miscellanecus rooms which are described in FSAR sections listed below.
The fuel handling building exhaust plenum treats exhaust air from the fuel handling building and discharges into the auxiliary building exhaust plenum. Upon receipt of a high radiation signal from the monitor in the fuel handling building exhaust air duct, the ef fluents are automatically routed through charcoal adsorbers and a HEPA filter. The system may also be operated upon initia-tion by the control room operator.
Sections 6.5.1, 9.4.1, and 9.4.5.1 of the Byron FSAR contain a detailed description of the three ESF filtered systems.
6.5.1.2 Evaluation and Findings _
We have reviewed all ESF filter systems with respect to the Acceptance Cri teria of Standard Review plan 6.5.1, dated November 24, 1975, and with respect to Regulatory Guide 1.52, -
Rev. 1.
As a result of this review, we have made the following evaluation and findings.
The applicant has not included either moisture separators or heaters in the non-accessible area exhaust filter system or the fuel handling building exhaust system. The applicant has installed
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i 4 6.5.1.2 cubicle coolers in some of the cubicles of various ESF system pumps. The applicant has indicated that the cubicle coolers are designed to limit the temperature in the cubicles to 122 F with l
the pumps operating, however, the applicant has not indicated that the relativity humidity will be controlled to 70%.
In the construction permit stage SER the staff took the position that relative humidity control to 70% was required for the in-coming air to the ESF filter systems and HEPA filters would be required downstream of the charcoal adsorters. The HEPA filters have been installed and a relative humidity control feature has been installed on the control, room makeup air system. However, such control features have not been added to either the non-accessible area exhaust filter system of the auxilisry building or the fuel handling building filter exhaust system. The applicant, in response to NRC question 321.23 provided an analysis of four different cases for the fuel handling building filter exhaust system, two summer and two winter. The worst case summer condition I
was inlet air with a dry bulb temperature of 95 F and a wet bulb temperature of 78 F.
At these temperatures, the relative humidity of the air to the filter system was calculated to be 48%. It is the staff's position that such a case is not indicative of the con-ditions that could be present during the course of an accident.
The daily maximum relative humidity in Byron area ranges from 87-92%
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6.5.1.2 during the summer months. The monthly average relative humidity is consistently over 72%. Although the applicant indicated that a similar study showed that no humidity control was required for the non-accessible area of the auxiliary building and that such a study was to be submitted to the staf f, none has been received. There-fore, since the staf f does not concur with the applicant's assump-tion of assigning a filter ef ficiency of 90% for the non-accessible area exhaust filter system or the fuel handling building filter exhaust system for organic radioiodines, an adsorter ef ficiency of 90% for elemental radioiodine and 50% for organic radioiodines has been assigned to the non-accessible areas exhauset filter system of the auxiliary building and 90% for elemental iodine and 70% for organic radiciodines for the fuel handling filter exhaust system.
The applicant 'has assumed 90% adsorber ef ficiency for all forms of radioiocine.
The applicant has not committed to record flow rate through the system as noted under acceptance criteria II.2.e of SRP 6.5.1.
This will be acceptable provided the fans are fixed speed fans and the applicant has a curve of flow rate versus pressure drop with pressure drop verified during plant operation on a routine basis.
Such a requirement will be made a part of the Byron technical specifications 3/4.7.6, 3/4.7.7 and 3/4.9.12.
O e 6.5.1.2 In the review of the ESF system, it was found that a number of i tems of SRP 6.5.1 were not addresse,d. These items included II.4.e-II.4.g. II.4.1-II.4.m, and II.5.b.
In addition, with res-pect to item II.4.j, the applicant has not provided cooling mechanisms in his design to remove the decay heat generated by iodine collection and charcoal oxidation. It is our position that the above items must be addressed satisfactorily in the FSAR prior to our acceptance of the design and that a cooling s3 stem is re-quired for the non-accessible area exhaust filter plenum and the fuel handling building exhaust system.
Section II.5 of SRP 6.5.1 is adoressed in Chapter 16.of the Byron FSAR under technical specifications. We have reviewed the proposed Byron technical specifications (3/4.7.6, 3/4.7.7, and 3/4.9.12) for the ESF filter systems. Based upon our review, these technical specifications will be acceptable if the following changes are made:
3/4.7.6 Control Room HVAC System 1.
Under the limiting condition for operation (LCO) exclude the enumeration of components which are required to be operable since such a list is not necessary and should also include passive components such as filters, adsorbers, etc.
2.
Laboratory analysis of charcoal adsorber samples should demonstrate a removal efficiency of 99% rather than 90% for 1
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. 6.5.1.2 methyl radioiodine since Section 6.5.1.1.1 indicates a removal efficiency of 95%. Surveillance requirements 4.7.6.1.c.3, 4.7.6.1.d.1, and 4.7.6.1.d.2 should also indicate a test that demonstrates 99% removal efficiency.
3.
Surveillance requirement 4.7.1.6.c should contain a require-ment to perfom a visual inspection of the system and its associated components prior to each in-place air flow distribution test, DOP test, or activatad charcoal adsorber leak test.
3/4.7.7 Auxiliary Building Exhaust Air Filtration System 1.
Surveillance requirement 4.7.7.1.a.4 should be changed so that the removal efficiency for methyl radioiodine is 99% if credit for 90% removal is deemed appropriate. The same comment holds for surveillance requirement 4.7.7.1.c.1 and 4.7.7.1.c.2.
2.
Surveillance requirement 4.7.7.1.b should contain a requirement to perfom a visual inspection of the system and its associated components prior to each in-place air flow distribution test, DOP test, or activated charcoal adsorber leak test.
3/4.9.12 Fuel Handling Building Exhaust Filter System 1.
Same comment as item 1 for 3/4.7.7 except comment pertains to surveillance requirements 4.9.12.b.4, 4.9.12.c.1, and 4.9.12.c.2.
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. 6.5.1.2 2.
Same comment as item 2 for 3/4.7.7 except comment pertains to surveillance reuirement 4.9.12.b.
3.
LCO should indicate that two of the 100% trains should be operable.
4.
Surveillance requirement 4.9.12.a.1 should indicate that flow is initiated on a staggered basis from the control room.
5.
Surveillance requirement 4.9.12.c.2.a should indicate 99%
removal efficiency for the radioactive methy1/radioiodine test if credit for 90% removal is deemed appropriate.
The above changes to the applicant's proposed technical specifica-tions will ensure consistency with the Standard Technical Speci-fications for Westinghouse reactors (NUREG-0452).
10.4.2 Main Condenser Evacuation System 10.4.2.1 Summary Description The main condenser evacuation system (MCES) of each unit consists of a mechanical vacuum pump which evacuates the main condenser upon startup and two 100% two stage steam jet air ejectors. During normal operation. the exhaust from the primary pumps and mechanical vacuum pump's air separator tanks and the steam jet air ejectors are discharged to each unit's vent stack. On a high radiation signal, flow can be diverted to a filter system which consists of a
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10.4.2.2 demister, electric heater, prefilter, HEPA filter, charcoal adsorber and another HEPA filter prior to release via the vent stack. A more detailed discussion of the system is presented in Sections 9.4.7.1 and 10.4.2 of the FSAR.
Evaluation and Findings The scope of our review included the system capability to process radioactive gases and the design provisions incorporated to monitor and control releases of radioactive materials in gaseous ef fluents in accordance with -GDC 60 and 64 of Appendix A to 10 CFR Part 50 and the quality group classification of equipment and components I
used to collect gaseous radioactive effluents, relative to the guidelines of Regulatory Guide 1.26.
The staf f reviewed the applicant's system descriptions, piping and instrumentation diagrams, and design criteria for components of the MCES with respect to SRP 10.4.2.
The basis for acceptance in our review has been conformance of the applicant's designs, design criteria, and design bases for the MCES to the applicable regulations, regulatory guides, and industry standards. Based upon our evalua-tion, we find the proposed main condenser evacuation system acceptable in all areas except the applicant has not indicated that the MCES meets the guidelines of " Standards for Steam Surface Condensers" as referenced by Acceptance Criterion 11.1 of SRP 10.4.2.
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10.4.3 Turbine Gland Sealing System 10.4.3.1 Summary Description The turbine gland sealing system proviaes sealing of the turbine generator shaft and the main feedwater pump turbine shafts against leakage of air into the turbine casings and the escape of radio-active steam into the turbine building. A portion of the main steam supply is passed through the turbine gland seals and condensed in the gland seal condenser. The condensate is returned to the main condenser hotwell while non-condensible gases are discharged to the ste'am jet air ejector exhaust header for eventual discharge to the vent stack. If the radiation monitor in this header indicates a high radiation signal, then flow will be diverted to the offgas filter system described in Section 10.4.2 of this SER.
10.4.3.2 Evaluation and Findings The staff has reviewed the turbine gland sealing system with respect to SRP 10.4.3.
The scope of this review included the source of sealing steam and the provisions incorporated to monitor and control releases of gaseous radioactive effluents in accordance with GDC 60 and 64 of Appendix A to 10 CFR Part 50. We have reviewed the applicant's system description and design criteria for the components of the turbine gland sealing system and found them consistent with Regulatory Guide 1.26. The basis for the acceptance in our review
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has been the conformance of the applicant's designs, design criteria, l
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. and design bases for the turbine gland sealing system to the applic-able regulations and regulatory guide referenced above. Based upon our evaluation, we find the proposed turbine gland sealing system
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acceptable.
11.0 Radioactive Waste Management 11.1 Source Terms 11.1.1 Summary Description The applicant calculated the liquid and gaseous effluents from the Byron Station utilizing the PWR GALE computer program. The applicant utilized the source assumptions of Regulatory Guide 1.112, "Calcula-tion of Releases of Radioactive Materials In Gaseous and L,iquid Ef fluents from Light-Water-Cooled Power Reectors", and NUREG-0017,
" Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents fran Pressurized Water Reactors (PWRs)". Gaseous effluents were calculated from such sources as offgases from the main condenser evacuation system; leakage to containment, fuel handling building, auxiliary building, and turbine building; noble gases stripped from the primary coolant during normal operation and at shutdown; and cover and vent gases from tanks and equipment containing radioactive material. Liquid ef fluents were calculated from such sources as shim bleed, leakage collected in equipment and floor drains of the turbine and auxiliary buildings, steam generator blowdown, contaminated liquids from anticipated plant operations such as resin sluices, filter backwash, decontamination solutions, sample station drains, and detergent wastes.
t 11.1.2 Evaluation and Findings The staff has performed an independent calculation of the primary and secondary coolant concentrations and of the release rates of radioactive materials using the infonnation supplied in the appli-cant's FSAR, the GALE computer program, and the methodology presented in NUREG-0017. Table 11.1-1 presents the principal parameters which were used in this independent calculation of the source terms.
These source terms were utilized in Section 11.2 and 11.3 to calcu-late individual doses in accordance with the mathematical models and guidance contained in Regulatory Guide 1.109, " Calculation of Annual Average Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I".
Liquid ef fluents occur from the boron recycle system, the steam generator blowdown subsystem and the non-blowdown radwaste subsystem.
The boron recycle system was assumed to treat letdown from the primary coolant system, valve leakoff and liquid collected in the reactor coolant drain tank. Additional information with respect to flow rates, DF's, fraction of primary coolant activity, etc., is contained in Table 11.1-1 under shim bleed and equipment drains and the boron recycle system. The non-blowdown radwaste treatsnent subsystem treats liquid wastes collected in the auxiliary building equipment and floor drain tanks, the regeneration waste drain tank, and the chemical drain
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11.1.2 tank. Additional information on the non-blowdown radwaste treatment subsystem can also be found in Table 11.1-1 and in particular under clean and dirty wastes. Information on the steam generator blowdown treatment subsystem is contained in the same Table.
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Airborne effluents occur from the normal ventilation system, from the waste gas decay tanks and the main condenser air ejector.
All airborne effluents except those released from the gas decay I
tanks and the main condenser air ejector exhaust are passed through HEPA filters prior to discharge.
The applicant has indicated in the FSAR that flow from the main condenser air ejectors can be diverted to a filter system consisting of a demister, electrical heater, prefilter, HEPA, charcoal adsorber, and a HEPA prior to release via the vent stack. However, the applicant did not indicate, based upon the noble gas release, at what corresponding I-131 release rate flow would be diverted to the filtration system.
It is the staff's position that no credit may be
.I given for such a filtration system which is not used on a continuous basis unless the applicant agrees to utilize such a system at a given release rate. Therefore, the fraction of iodine activity which was assumed to be released from the main condenser air ejectors was 1.0 rather than 0.10 the value it would have been if credit were i
given.
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\\ 11.1.2 In our review of the applicant's input parameters to the GALE Code which are presented in Table 11.2-2 of the FSAR the fraction of primary coolant activity associated with the clean wastes, dirty waste and equipment drain streams were lower than those values l
assumed by similar plants. Insufficient infomation and, in some cases, conflicting infomation in Section 11.2 of the FSAR did not allow the staff to verify the applicant's values. Therefore, the staff based the values for these parameters on what it censidered the best infomation presented in the FSAR together with some con-servative assumptions. Thus, the staff's source terms for liquid ef fluents may be overestimated with respect to actual releases.
~
Likewise, the gaseous source tera for radioiodine from the main condenser air ejectors may be overestimated since no credit was given for the use of the charcoal adsorter and HEPA filters on an intermittent basis.
l The applicant is installing a fluidized bed dryer to process evap-orator bottoms and a dry waste processor to incinerate contaminated oil and compactible and combustible trash. The purpose of this equipment is to reduce the volume of solid radwaste shipped offsite l
from the station. The operation of this volume reduction (VR) equipment will result in additional liquid and airborne effluents.
l Airborne ef fluents will result froa the VR system's offgas and will be discharged on a continuous basis while the system is operating.
l
. 11.1.2 There are no liquid effluents which will be discharged directly off-site as a result of VR equipment operation. However, based upon the Aerojet Energy Conversion Company Topical Report No. AECC-2 P entitled, " Radioactive Waste Volume Reduction System", which was referenced by the applicant, the operation of the VR system will result in the pumping of decontamination solutions back to an evaporator feed tank, the return of condensate from the VR system condenser sump, and the pumping of scrub solution back to the evaporator feed tanks when operating in the incineration only mode.
These streams will result in additional quantities of wastes being treated by the radwaste evaporators. U1'.,imately, some of these wastes will be discharged offsite from the release tank and some will be treated in the VR system.
The applicant has not addressed (1) the volume of wastes to be handled by the VR system; (2) the radioactivity associated with this volume of waste; (3) the quantity of airborne effluents released from the VR system; (4) the additional volume of wastes to be treated by the liquid radwaste system as a result of operation of the VR system; and (5) the liquid effluents resulting from this liquid source. Since the GALE program does not have the capability of predicting such information, the staff has estimated the quantity of wastes to be treated by the VR system and the radioactivity associated with these wastes. The staff has estimated the additional
~
. 11.1.2 amount of radiaoctivity released as airborne ef fluents from the VR system and as liquid effluents from the liquid radwaste system.
These releases were included with the releases calculated using NUREG-0017 and the total quantity of ef fluents was presented in Section 5 of the Byron Draft Environmental Statement (DES).
Table 11.1-1 presents assumptions which were utilized in the cal-culation of effluents resulting from VR equipment. The applicant has not filed with the Commission details on the VR system design and its interface with various plant systems. Such infonnation will 'be required prior to approval o? the stations radwaste VR systems.
11.2 Liquid Radwaste System 11.2.1 Summary Description The liquid radwaste system at Byron consists of process equipment and instrumentation necessary to collect, process, monitor, and recycle and/or dispose of radioactive liquid wastes. The liquid radwaste system is designed to collect and process wastes based on the origin of the waste in the plant and the expected levels of radioactivi ty. All liquid waste except steam generator blowdown is processed on a batch basis to permit optimum control of releases.
Before liquid waste is released, samples are analyzed to detennine the types and amounts of radioactivity present. Based on the results of the analysis, the waste is recycled for eventual reuse in the plant, retained for further processing, or released to the environment
Table 11.1-1 Principal parameters and conditions used in calculating releases of radioactive material in liquid and gaseous effluents from Byron, Units 1 and 2 Reactor power level (MWt) 3565 Plant capacity factor 0.80 Failed fuel 0.12%a Primary system 5
Mass of coolant (1b) 4.7 x 10 Letdown rate (gal / min) 75 3
Shim bleed rate (gal / day) 2.16 x 10 Leakage to secondary system (1b/ day) 100 Leakage to containment building (1b/ day) b Leakage to auxiliary building (1b/ day) 160 Frequency of degassing for cold shutdowns (times /yr) 2 Letdown cation demineralizer flow (gal / min) 7.5 Secondar, system 7
Steam flow rate (1b/hr) 1.5 x 104 Mass of liquid / steam generator (1b) 9.3 x 103 Mass of steam / steam generator (1b) 9.5 x 106 Secondary coolant mass (1b) 2.0 x 103 Rate of steam leakage to turbjne area -(1b/hr) 1.7 x 10 2.8 x 106 Containment building volume (ft )
Frequency of containment purges (times /yr) 6 3
Containment low volume purge rate (ft / min)
O Containment atmosphere cleanup rate (ft / min) 1.6 x 104 3
Pre-purge cleanup time duration (hr) 16 Iodine partition factors (gas / liquid)
Leakage to auxiliary building 0.0075 Leakage to turbine area 1.0 Main condenser / air ejector (volatile species) 0.15 Liquid radwaste system decontamination factors Boron Recycle Non-blowdown Steam Generator Material System Radwaste System Blowdown System 1x10l 1 x 10f Iodine 1 x 103
5 2
Other 1 x 10 1 x 10 1 x 10 t
aThis value is constant and corresponds to 0.12% of the operating power product source term as given in NUREG-0017 (April 1976).
l bl%/ day of the primary coolant noble gas inventory and 0.001%/ day of l
the primary coolant iodine inventory.
l l
l
Table 11.1-1 (continued)
Individual equipment decontamination factors 1.
Evaporator All nuclides System except iodine Iodine Non-blowdown radwaste system, radwaste evaporator 4
3 decontamination factor 10 10 Boron recycle system, recycle evaporator decontamination 3
2 factor 10 10 2.
Demineralizers
10 2
10 3 3 Primary coolant letdown cation demineralizer decontamination factor 1
10 10 Primary coolant letdown mixed bed demineralizer (1.1 B0 )
10 2
10 3 3 Boron recycle evaporator condensate demineralizer 2
( Anion)~
10 1
1 2
2 Steam generator blowdown demineralizer 10 10 10 Radwaste mixed bed polishing demineralizer 10 10 l'J Liquid Waste Inputs Decay Flow Rate Fraction Fraction Collection Time Stream (gal / day) of PCA Discharged time (days)
(days)
Shimbleed Rate 2160 1.0 0.1 20.3 2.31 Equipment Drains 300 1.0 0.1 20.3 2.31 Clean Wastes 5600 0.3 1.0 1.14 0.15 Dirty Wastes 3850 0.044 1.0 1.14 0.08 1.0 0
0 Blowdown 173000 Gaseous Waste Inputs There is not continuous stripping of full letdown flow Holdup time for xenon (days) 36.4 Holdup time for krypton (days) 36.4 Fill time of decay tanks (days) 36.4
^
s Table 11.1-1 (Continued)
Total Source of Volume Reduction System Wastes Volume / Year Activity (Ci/yr) 1.
Evaporator Bottoms 8,500 ft 370 3
5 2.
Comtustible Trash 10,000 f t 3.
Contwninated Oil 500 gal 1.9 x 10~'
J'[
~ ' ' '
Decontamination Factors Volume Reduction Equipment Iodine Others s
1.
Fluidized bed dryer or dry waste 2
'100 J
processor / gas / solids separator 2.
Scrubber /Preconcentrator 3
100 3.
Recycle Air stream 3
1 4.
HEPA filter 1
100 5.
Charcoal adsorter 100 1
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h e
W 9
'4
s u c
s
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a J
s, 7
N N
E
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- s s
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11.2.1
. under controled conditions.
A radiation monitor in the discharge s...
x
- ~, line will automatically tenninete liquid waste discharges if radia-s s,
tion measurements exceed a predctennined level,-
'x, w.,,,.; ~ ~
4-3
,~
The liquid radraste. system at,yyron is camposed of two subsystems:
s
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(1) ihi steam gencr'atori18'doNsubsystem, and
':'N (2) thefon-310wdpin h$dw'a'st(s'ubsyqtent.'
s'
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t The steam ge'nprator blowdown (S'GB) suosy, stem treats the blowdown
- ~ b, Y,
", from the steam' generators. by passing ft through a prefilter, a
,w mixed bed emineral.12er,'and in afterfilter. The blowdown is x
~
collected in the blowdown monitor tank. If the b1cwdown is to be
~
released offsite it-is pihtiped from 'the :nonitor tark to the release tank..The SGB subsystei of Dnit 2-also treats the liquid wastes collected in the turbine building equipnier.t drain tanks.
Inh r)on-blowdown radwaste subsystem treats liquid wastes collected
.8 l
in:
(1) auxiliary building floor drain tanks; 12)~ a'uxiliary, building.cquipment drain tanks; (3), chemic'ai drain tank;,
(4) regeneration' waste hain tank.
O.
These wastes are treated by filtration, evaporation, polishing de-mineralization, and filtration prior to collection in the radwaste t
N i
l l
l
. ~
11.2.1 monitor tank. From the radwaste monitor tank the wastes may be pumped to the release tank for offsite discharge, reprocessed, re-cycled to the condensate storage tank, or recycled to the primary water storage tanks via the recycle vacuum deaerator.
The waste collected in the laundry drain tank and the turbine building floor drain tanks are filtered prior to collection in the release tank. All intended offsite ifquid releases from Byron occur from the release tank.
The liquid radwaste system at Byron is shared between Units 1 and 2 with the exception that each unit has separate equipment and floor drain sump systems. However, Units 1 and 2's blowdown is normally segregated through the recycle phase since Unit 1 and 2's condensate storage tanks are normally scgregated.
The liquid radwaste system consists of a number of crossties which allows alternative treatment schemes to those discussed above.
Further detail on the liquid radwaste system and these treatment schemes is pretided in Section 11.2 of the Byron FSAR.
The structures housing the liquid radwaste system are Safety Category I (Note FSAR definition in Section 3.2) for the auxiliary building and Safety Category II for the turbine and radwaste buildings.
All components of the liquid radwaste system containing radioactive
o 11.2.1 waste including tanks, pumps, valves, and piping) are Quality Group D with the exception of the spent resin tank which is Quality Group C, and the containment penetration piping out to and including the second isolation valve from the containment sump pump discharge, which are Quality Group B piping and valves. Additional information on specific seismic categorization is contained in Table 11.2-1.
The liquid radwaste system is designed to the guidelines of Regulatory Guide 1.143.
11.2.2 Evaluation and Findings The liquid radwaste system was reviewed with respect to Standard Review Plan 11.2.
Our review conside. red the capability of the proposed liquid radwaste treatment system to meet the anticipated demands of the station due to anticipated operational occurrences and we have concluded that the system's capacity and design flexi-bility are adequate to meet the anticipated needs of the station.
The potential consequences resulting from reactor operation have also been considered and we have determined the concentrations of radioactive materials in liquid ef fluents in unrestricted areas to be a small fraction of the limits in Table II, Column 2 of Appendix B to 10 CFR Part 20.
In addition, we have determined that the proposed liquid radwaste system is capable of maintaining releases of radioactive materials in liquid effluents such that
..~
l
. 11.2.2 the calculated individual doses in an unrestricted area from all pathways of exposure are less than 3 millirem to the total body I
and 10 millirem to any organ.
We have also considered the potential consequences resulting from reactor operation with 1% of the operating fission product inventory in the core being released to the primary coolant and have determined that the concentrations of radioactive materials in liquid ef fluents in unrestricted areas will be a small fraction of the limits of Table 2, Column 2 of Appendix B to 10 CFR Part 20.
As discussed in Section 11.1 of this SER, the staf f calculated liquid effluents using the GALE computer program based upon the treatment systems for liquid ef fluents described above. These source terms were presented in Section 5 of the Byron DES.
We calculated the doses to offsite individuals utilizing the method-ology of Regualtory Guide 1.109 and the liquid dispersion parameters calculated in accordance with Regulatory Guide 1.113, " Estimating Aquatic Dispersion of Effluents from Accidantal and Routine Reactor Releases for the Purpose of Implementing Appendix I". We also cal-culated the releases resulting from liquid wastes gancrated by the VR system. We have determined that the proposed liquid radwaste treatment systems are capable of maintaining releases of radioactive
k 11.2.2 materials in liquid effluents such that the calculated individual doses in an unrestricted area from all pataways of exposure are less than 3 mrem to the total body and 10 mrem to any organ.
2 We have calculated, as noted in Section 11.1, the release of radioactive materials in liquid effluents exclusive of tritium and noble gases and have found it to be less than 5 C1/yr per reactor and the annual dose to any organ of an individual in an unrestricted area to be less than 5 millirem per year total from both reactors.
Therefore, in accordance with the option to Section II.D of Appendix I as provided in Annex to Appendix I of 10 CFR Part 50, the staff finds that the liquid radwaste system is capable of reducing liquid radioactive effluents to "as low as is resonably achievable" levels in accordance with 10 CFR Part 50.34a of Appendix I to '10 CFR Part 50 and the Annex to Appendix I.
The Byron DES presents a comparison of the RM 50-2 and Appendix I design objective doses with the doses calculated for the liquid source terms and e comparison of the RM 50-2 curie limitation with the projected releases for the Byron Station.
The applicant has stated in the FSAR that the liquid radwasto system meets the design criteria of Regualtory Guide 1.143.
The design of the liquid radwaste presented in the FSAR is different from that which was proposed at the Construction Pemit (CP) stage.
Table 11.2-1 Design parameters of principal components considered in the evaluation of liquid and gaseous radioactive waste treatment systems of Byron Units 1 and 2 Capaci ty Seismic Quali ty Component Number (each)
Category Group Liquid Boron Recycle System Evaporator Feed Demineralizer 2
120 gpm I
C Holdup Tank 2
125,000 gal I
Evaporator Feed Pump 2
30 gpm I
Evaporator Feed Filter 2
150 gpm I
Evaporator 4
15 gpm I
Evaporator Condensate Demineralizer 1
120 gpm II D
Evaporator Condensate Filter 1
35 gpm II Monitor Tank 2
20,000 gal II Monitor Tank Pump 2
250 gal II Steam Generator Blowdown Subsystem Blowdown Condenser 2
360 gpm II D
Hotwell Tank 2
300 gal II Blowdown Condenser Hotwell Pump 4
250 gpm II Blowdown Prefilter 4
250 gpm II Blowdown Mixed Bed Demineralizer 4
180 gpm II Blowdown After Filter 4
250 gpm II Blowdown Monitor Tank 3
20,000 gal II Blowdown Monitor Tank Pump 3
350 gpm II Non-Steam Generator Blowdown Subsystem Chemical Drain Tank 2
6,000 gal II D
Chemical Drain Tar,k Pump 2
60 gpm II Chemical Drain Tank Filter 2
150 gpm II
)
Regeneration Waste Drain Tank 2
10,000 gal II Regeneration Waste Drain Tank Pump 2
60 gpm II Regeneration Waste Drain Tank Filter 2
150 gpm II Aux. Bldg. Equipment Drain Tank 4
8,000 gal II Aux. Bldg. Equipment Drain Tank Pump 4
60 gpm II Aux. Bldg. Equipment Drain Tank Filter 2 150 gpm II Aux. Bldg. Floor Drain Tank 4
8,000 gal II Aux. Bldg. Floor Drain Tank Pump 4
60 gpm II l
Aux. Bldg. Floor Drain Tank Filter 2
150 gpm II Laundry Drain Tank 1
4,000 gal II Laundry Drain Tank Pump 1
30 gpm II Laundry Drain Tank Filter 1
150 gpm II 1
Laundry Waste Storage Tank 2
2,000 gal II Laundry Waste Storage Tank Pump 2
25 gpm II Turbine Bldg. Equipment Drain Tank 2
12,000 gal II Turbine Bldg. Equipment Drain Tank Pump 2 90 gpm II Turbine Bldg. Equipment Drain Tank i
Filter 1
150 gpm II Turbine Bldg. Floor Drain Tank 2
12,000 gal II Turbine Bldg. Floor Drain Tank Pump 2
90 gpm II Turbine Bldg. Floor Drain Tank Filter 1
150 gpm II
_.,-4e...w i-g
Table 11.2-1 (continued)
Capaci ty Seismic Quali ty Component Number (each)
Category Group Radwaste Evaporator 3
30 gpm II D
Radwaste Mixed Bed Demineralizer 3
45 gpm II Radwaste Demineralizer Af terfilter 3
150 gpm II Radwaste Monitor Tank 2
20,000 gal II Radwaste Monitor Pump 2
350 gpm II Release Tank 1
30,000 gal II Release Pump 1
500 gpm II Spent Resin Storage Tank 1
I C
Spent Resin Pump 2
II D
Decanting Tank 2
500 gal II Concentrate Holding Tank 1
6,400 gal II Gaseous 3
Waste Gas Compressor 2
40cfg I
C Gas Decay Tanks 6
600 ft I
C l
l l
1 j
. At the CP stage the SGB subsystem was intended to process SGB con-tinuously through a blowdown evaporator and polishing demineralizers with the water reused in the station. The present scheme treats SGB by demineralization with either reuse or discharge of fsite.
4 At the CP stage laundry wastes were to be treated by reverse osmosis and evaporation with the liquid either recycled or discharged. The present intended treatment is for the laundry wastes to be filtered and then discharged. However, the capability is present in the liquid radwaste for the SGB and the laundry wastes to' be treated by the radwaste evaporators but that is not the intended mode of treatment.
We find that these design changes still result in the station meeting
~
the requirements associated with SRP 11.2.
Based upon the foregoing evaluation we conclude that the proposed liquid radwaste treatment system is acceptable. The basis for this acceptance has been the confomance of the applicant's design, design criteria and design bases for the liquid radwaste system to the Commission's regulation, regulatory guide and acceptance criteria of the standard review plan for this system.
11.3 Gaseous Waste Management System 11.3.1 Summary Description The gaseous waste management systems at the Byron Station include systems which treat the nomal ventilation exhausts; the exhaust from
O l 1 11.3.1 the main condenser air ejectors, hogging pumps and gland steam j
condensers; and the gaseous wastes associated with degassing primary coolant, purging the volume control tank, displacing cover gases, purging of equipment, sampling and gas analysis operations, and boron recycle process operations.
i Table 11.3-1 provides a listing of the various nomal ventilation systems at the Byron Station and the type of treatment associated l
with each system. Additional details are provided in Sections 6.5.1 and 9.4 of the FSAR.
If a generalization can be made of the nomal ventilation exhaust treatment systems at Byron, it is that the i
exhausts usually flow through a prefilter and a HEPA filter.
Exceptions are the non-accessible area and fuel handling building ESF-grade systems which possess the capability of diverting flow to a charcoal adsorber and another HEPA on a high radiation signal.
The off-gas filter system denoted in Table 11.3-1 is the filtration system associated with the main condenser air ejector and turbine gland sesi condensers and was discussed previously in Sections 10.4.2, 10.4.3 and 11.1 of this SER.
The gaseous waste processing system consists of two waste gas compressor packages, six 600 ft gas decay tanks, and a sequential l
gas analyzer for H /0. The gaseous waste processing system serves 2 2 1
both units. This system collects the gases from degassing the l
l
. 11.3.1 reactor coolant, purging the volume control tank, displacing cover gases, sampling and gas analyses, and boron recycle process operation.
Further detailed discussion of the ventilation and waste gas systems is contained in S?ctions 6.5.1, 9.4, 10.4.2, 10.4.3, and 11.1 of the FSAR.
Those gaseous waste management systems which are located in the containment, auxiliary and fuel handing buildings are located in Safety Category I (Note FSAR definition in Section 3.2) structures.
All other structures are Safety Category II. Those components of the gaseous waste management system which are Safety Category I, Quality Group C are listed in Table 11.3-2. Those which are Safety Category II, Quality Group D are also listed in this Table.
For the gaseous waste processing system, a samole is taken of the gas decay tank to be discharged and analyzed. The inventory is determined from the analysis and the pressure in the tank. When the contents of the gas decay tank are released the local manual stop valve is opened to the plant vent and the gas discharge modulating valve is opened. On a high radiation signal in the vent, the modulating valve closes.
11.3.2 Evaluation Findings The gaseous waste management system was reviewed with respect to the acceptance criteria of SRP 11.3.
At the CP stage, the building
, _ _.. _ _ _ - _. _ _ _-- ~ - - -
. 11.3.2 ventilation systems of the auxiliary, radwaste, and fwl handling buildings included a HEPA and a charcoal adsorter on-line at all times as did the main condenser air ejectors exhaust. As noted above, these building ventilation systems, as proposed, will utilize only a HEPA filter on a routine basis. No credit was given for filtation of main condenser exhaust as noted in Section 11.1 of thi s SER. -
As discussed in Section 11.1 of this SER, the staf f calculated gaseous effluents using the GALE computer program based upon the treatment systems for gaseous effluents described above. These source tenns were presented in Section 5 of the Byron DES.
The staff has calculated the doses to offsite individuals utilizing the methodology of Regualtory Guide 1.109 and the atmospheric dis-persion parameters calculated in accordance with Requiatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors". The staff also calculated the releases resulting from gaseous effluents from the VR system. The staf f has determined that the proposed gaseous radwaste treatment systems are capable of maintaining releases of radioactive materials in gaseous effluents such that the calculated individual doses in an unrestricted area from all pathways of expcsure are less than 5 mrem to the total
. 11.3.2 body and 15 mrem to any organ from noble gases and that releases of radiolodine and radioactive material in particulate form result in doses which are less than 15 mrem to any organ.
The staff has also considered the potential effectiveness of aug-menting the proposed gaseous radwaste treatment systems using items of reasonably demonstrated technology. The applicant has chosen to show compliance with Section 11.0 of Appendix I to 10 CFR Part 50 by complying with the Annex to Appendix I (RM 50-2). The Byron DES presents a comparison of the doses and release calculated for Byron with the design objectives of Appendix I and RM 50-2.
The applicant's proposed design complies with the design objectives of RM 50-2, therefore, we have determined that no further effluent treatment equipment will reduce the cumulative population doses within a 50 mile radius in a cost effective manner.
The staff has also considered the potential consequences resulting from reactor operation with 1% of the operating fission product inventory in the core being released to the primary coolant and has determined that the concentrations of radioactive materials in gaseous effluents in unrestricted areas will be a small fraction of the li.aits of Table 2, Column 1 of 10 CFR Part 20.
The capability of the proposed gaseous radwaste treatment systems to meet the anticipated demands of the plant due to operational
. 11.3.2 occurrences was also considered and it was concluded that the system capacity and design flexibility is adequate to meat the anticipated needs of the station.
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 system and the structures housing the radwaste systems was also reviewed. The design of the systems and the structures housing these systems meet the criteria set forth in Regulatory Guide 1.143 as indicated by the applicant in Appendix A to the FSAR.
However, the staff finds that the gaseous waste processing system does not meet the acceptance criteria II.6.b of SRP 11.3 in that, since the system is not designed to withstand an explosion, dual gas analyzers with automatic control _ functions, which are required, are not included with the system such as to preclude the fonnation or buildup of explosive H /0 mixtures. The monitor proposed for this 2 2 system includes a single sequential analyzer and the automatic control al arm.
feature is for the tank being filled to be isolated on an 02 If the source of the 0 is the compressor then isolating the tank 2
does not correct the problem; it only diverts it.
1 It is the staff's position that this may be corrected by the applicant choosing one of the following alternatives:
monitoring ooint between the (1) Installing of a continuous H /02 2
?
. ~
11.3.2 compressors and the gas decay tanks utilizing the sequential analyzer as the redundant analyzer.
(2) Allow the existing H /0 monitoring system to operate with 2 2 the additional requirements that upon a high-high alarm the automatic control features will include the injection of dilutents to reduce the concentrations below a given concen-tration, as long as sufficient holdup time can still be achieved. In addition, the Byrcn technical specifications will include a requirement to sample and analyze every four hours during a gas monitor outage and to bring the reactor to the cold shutdown condition if the gas monitor outage exceeds seven days.
The gaseous waste processing system has also been judged inadequate in that the applicant's Section 11.3 has not addressed the capability of the gaseous waste system design to stop leakage paths as noted in Acceptance Criteria II.3 of SRP 11.3.
It is the staff's position that this must be addressed prior to approval of the gaseous waste processing system.
The staff has reviewed the normal ventilation system's design, testing and maintenance wof HEPA filters and charcoal adsorbers, with respect to Regulatory Guide 1.140. The applicant has provided in Appendix A cf the FSAR exceptions to this Regulatory Guide. The staf f has reviewed these exceptions.
In one exception the applicant has i
+
1 l i 11.3.2 indicated the all of the filter systems equipment was specified and purchased prior to issuance of this regulatory guide and that the filters are of identical quality and construction to that of safety related system components and that no in-place testing will be per-formed. In our evaluation and the applicant's evaluation of the normal ventilation systems for the purpose of calculating source terms to show compliance with Appendix I, a certain filter efficiency for various filter systems was assumed. Without an in-place testing program there is no guarantee that the filters and the systems are performing as designed. Therefore, to ensure that our Appendix I evaluation is not negated, it is our position that the normal ventilation systems must undergo periodic in-place testing. With respect to testing these systems, we have a concern whether the applicant will be able to test the containment purge filter system in accordance with ANSI N510-1976 because of its high flow rate (94,000 cfm). Therefore, the staf f's position is that the applicant should submit information that verifies that the testing equipment is capable of generating sufficient aerosol to test this containment purge filter system.
Upon the resolution of the above described items, the gaseous waste management system will be judged to be acceptable.
Table 11.3-1 Byron /Braidwood Filtration Systems for Normal Ventilation Moisture Electrical Pre-Charcoal Separator heater filter HEPA adsorber HEPA N
N H
H
- 1. Non accessible area (see Section 6.5.1 of SER for descrip-tion of sources), 3-50%
systems N
N
- 2. Accessible area exhaust filter plenum, 4-33%
systems N
N H
H
- 3. Fuel handling b1dg.
exhaust, 2-100% systems
- 4. Laboratory HVAC (common)
N N
a) Fume hood exhaust filter train N
b) Laundry room exhaust N
filter train N
N
- 5. Radwste b1dg. ventilation system
- 6. Turbine area ventilation system
- 7. Of f-gas filter system H
H H
H H
H
's
- 8. Miscellaneous tank vent N
N N
N N
N (from filters, heat ex-changers, tanks)
N N
- 9. Containment purge H
H H
H
- 10. Post-LOCA purge
- 5eparate system for each unit.
N - Operates under normal conditions.
H - Operates on a high radiation signal.
t
+
~
Table 11.3-2 Safety category and quality group classification of various components of the gaseous waste management system at Byron 1
A.
Safety Category I, Quality Group C (1) Waste gas compressors (2) Gas decay tanks (3) Auxiliary building HVAC B.
Safety Category II, Quality Group D (1) Auxiliary building filtered and non-filtered vents (2) Containment filtered and non-filtered vents (3) Laboratory HVAC C.
Safety Category II (1) Containment charcoal filter unit (2) Containment charcoal filter fan (3) Containment charcoal filter fan motor (4) Containment purge exhaust fan (5) Containment purge exhaust fan motor (6) Containment purge exhaust fan filters (7) Miscellaneous ventilation (8) Radwaste facility ventilation
t l 11.4 Solid Waste Management Systems 11.4.1
System Description
The solid radioactive waste system is designed to process two general types of solid wastes: " wet" solid wastes and " dry" solid wastes.
Wet solid wastes consist mainly of spent filter cartridges, demin-eralizer resins, and evaporator bottoms which contain radioactive materials removed form liquid streams during processing. Dry solid wastes, consisting mainly of ventilation air filtering medium (HEPA, charcoal), contaminated clothing, paper, rags, laboratory glassware, and tools.
Spent filter cartridges will be placed in drums unsolidified for disposal. For those filters which contain large amounts of' radio-active material the drum will be precast concrete lined. Demin-eralizer resins will be solidified in 55-gallon drums using portland cement.
Two methods of treatment will be available for evaporator bottoms and dry compactible trash. Evaporatoi bottoms can be solidified in 55-gallon drums using portland cement. Dry compactible trash can be compacted in 55-gallon drums. Alternatively, both types of wastes may be treated in the volume reduction system. Evaporator bottoms can be calcined in a fluidized bed dryer where they will be reduced in volume and increased in activity per unit volume.
. 11.4.1 The dry salts from the fludize bed dryer and the fines collected at the gas / solids separator of the VR system will then be solidified using a polymer binder. Compactible trash is also capable of being volume reduced in the dry waste processor (incinerator) which is also a fludized bed. The ash from the dry waste processor will be carried by the fludizing air to the gas / solids separator where most of the ash will be removed from the gas stream. This ash will be combined with the calcination fines collected in the same gas / solids separator and the salt from the fluidized bed dryer and solidified using a polymer binder.
The gas from the gas / solids separator will flow to a venturi scrub-ber/preconcentrator to a secondary scrubber and to a condenser. A portion of the gas will be recycled to the fludized bed dryer while a portion will be discharged through a HEPA, charcoal and HEPA filter system prior to release to the vent stack. The evaporator bottoms will be increased in solids concentration in the scrubber precon-centrator. This liquid will be pumped to the fludized bed dryer or recirculated to the venturi scrubber. The dry waste processor will also be capable of incinerating contaminated oil.
The applicant will have a low level storage area which will store 570 drums and an intermediate level storage area capable of storing 640 drums. The station will contain areas capable of storing 70 drums of compactible waste and 90 ft of dry uncompacted waste.
g
. 11.4.1 Additional information with respect to the solid radwaste system is contained in Section 11.4 of the FSAR and in Aerojet Energy Conver-sion Company topical report AECC-2-P which describes the volume reduction system.
11.4.2 Evaluation and Findings The staff has reviewed the portand cement portion of the solid waste system (SW3) which is one of the systems intended to be used for the solidification, packaging, and storage of radioactive wastes prior to shipment offsite for burial. The scope of the review included line diagrams of the system, piping and instrumentation diagrams (P& ids), and descriptive information 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 design bases for the SWS, and the applicant's analysis of those criteria and bases have also 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 accord-ance with General Design Criterion 60, provisions for the handling of wastes relative to the requirements of 10 CFR Parts 20 and 71 and of applicable DOT regulations have been reviewed.
The portland cement portion of the SWS has also been reviewed with respect to SRP 11.4 and Regulatory Guide 1.143. Based upon the
11.4.2 above review, we find that a conclusion with respect to the acceptability of this portion of the SWS cannot be made because:
(1) Section 11.4 of the FSAR has not addressed the capability of the SWS to meet the design criteria, quality assurance requirements and construction and testing criteria of Regulatory Guide 1.143 as discussed in Acceptance Criteria II.3,11.4, and 111.4 of SRP 11.4.
(2) The applicant has not provided information which discusses what design and operational changes have been instituted as a result of their engineering evaluation of industry operating experience with various solid waste systems.
The staff has not reviewed the VR system or the polymer binder system as to their conformance with SRP 11.4 and Regulatory Guide 1.143. The applicant has not provided any information on the polymer system and has referenced the Aerojet Energy Conversion Company topical report AECC-2-P as the source for details on the VR system. The staff is in the process of reviewing this topical report. As a result of this review, generic questions will be asked on the system. Mcwever, detailed questions will be asked of the applicant with regard to the application of the Aerojet design to the Byron Station. The staff anticipates the information required of the applicant will be considerably greater than that presently in the FSAR. Until the above reviews are completed, l
e, D ~
11.4.2 information requested of the applicant, and responses received and reviewed; no determination may be made as to the acceptability of the SWS.
The applicant has not provided the Process Control Program or the technical specifications for the SWS. These items are not required until 6 months prior to the issuance of the Operating License. They will be judged as to their acceptability at that time.
11.5 Process and Effluent Radiological Monitoring and Sampling Systems 11.5.1 Summary Description The process and effluent radiological monitoring and sampling systems are designed to provide infomation concerning radioactivity levels i,n systems throughout the plant, indicate radioactive leakage between systems, monitor equipment and perfomance, and monitor and control radioactivity levels in plant discharges to the environs.
At the Byron Station, the airborne effluent sampling and monitoring systems are located at the plant vents. For liquid effluents, these locations are downstream of the liquid radwaste system's release j
tank and in the stations blowdown line to the Rock River.
Table 11.5-1 contains a listing of both the process and effluent monitors for airborne and liquid sources. This Table also includes the type of radioactivity monitored, the type of monitor used, and
1 -
11.5.1 the plant specific number of the monitor for ease of reference.
Section 11.5 of the FSAR presents a detailed analysis of the process and effluent monitoring system.
11.5.2 Evaluation and Findings We have reviewed the process and effluent montioring system with respect to the Acceptance Criteria of SRP 11.5, Revision 2.
As a result of this review, we have made the following evaluation and findings.
The process and effluent montioring system provides for monitoring and sampling all normal and potential pathways for the release of radioactive materials to the environment. However, the process '
portions of the non-blowdown liquid radwaste system and the spent fuel pool treatment system do not have contineous monitoring cap-l ability, as indicated in Table 1B, SRP 11.5.
With respect to the non-blowdown liquid radwaste system, the FSAR also indicated in Section 11.2.1.10 that waste collected in the radwaste monitor tanks would be sampled prior to discharge to the release tank.
As long as this process includes analysis of the sample and as long as this process continues a continuous process monitor will not be j
required for the non-blowdown liquid radwaste system.
s 11.5.2 The applicant has indicated in Section 12.3-4 that there is an airborne gamma radiation detector in the area of the spent fuel pool capable of detecting activity over the range 0.1-100 mr/hr.
This monitor does not replace the function af a liquid monitor in the spent fuel pool, as required by Table 1B. However, Revision 3 to SRP 11.5 does not require such a monitor if no liquid ef fluent occurs from the spent fuel pool. Since the applicant has proposed to perform a weekly grossf, grossY, and radionuclide analysis on the outlet and inlet streams of the spent fuel pool demineralizer, no process monitor is required.
Table IB of SRP 11.5 indicates that a grab sample should be obtained in the process stream from laboratory and sample system wastes. These wastes are drained to the chemical drain tank which will be sampled as noted in the FSAR. Sampling at this location will satisfy the intent of Table IB of SRP 11.5.
The FSAR indicates that a grab sample will be taken of the component cooling water. However, it is not clearly stated whether the purpose of the sample is to analyze for the purpose of detecting radio-activi ty.
If that is the intent, then the criteria of Table IB will be satisfied. The FSAR should be modified to reflect the types of analyses to be performed.
y
- 11.5.2 Acceptance criterion II.2.a of SRP 11.5 states that recirculation 4
pumps for liquid waste tanks (collection or sample tanks) should be capable of recirculating two tank volumes in approximately eight hours. The laundry waste storage tank ptsnps do not possess i
such a capability. They can recirculate two tank volumes in approximately 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />. Therefore, the applicant must propose some alternative scheme for the laundry waste storage tanks to ensure that representative samples are obtained.
The applicant has either failed to address the following items of SRP 11.5 or has not provided sufficient detail to allow the staff to ccmplete our evaluation:
(1) provisions for purging sample lines and for reducing plateout in sample lines of process streams; (2) monitoring instrumentation specifications and perfonnance criteria such that it may be compared to ANSI N13.10-1974; or (3) provisions in the design of the system such that replacing detectors or decontaminating monitors may occur without i
opening the process system or losing the capability to i
isolate the system or divert the effluent to a standby treatment system.
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\\
. 11.5.2 The applicant has not addressed what process and effluent monitoring j
would be associated with the volume reduction equipment. Such infomation is required of the applicant, i
Until all the abwe infomation is provided, no conclusions can be drawn with respect to the General Design Criteria 63 of 10 CFR Part 50.
l l
Our review of the process and effluent monitoring system has not I
addressed some items of SRP 11.5. Those items which were not addressed will be reviewed at the time the radiological effluent technical specifications are submitted by the applicant. Those areas of the process and effluent montforing system which will be reviewed at that time include:
(1) sampling frequencies, required analyses, instrument alarm / type set points, calibration, and sensitivities; (2) frequency of routine instrument calibration, maintenance, and inspections; and l
(3) release rates.
In addition, process and effluent monitoring and sampling system provisions during the course of postulated accident have not been r
addressed by the applicant. These items will be addressed at least l
i 4 months prior to issuance of the operating license.
l i
A
Table 11.5 1 Ltquid and airborne process and ef fluent menitoring systs*
Table 11.5-1 at the Byron Station (continued)
Monito r Monitor Monitor Monitor No.
Monitoring Type Monitor Monitor No.
Monitorine Type Process A.
Airborne 8.
Gas Decay Tank ORE-PR002A Gas 8$ cts.
1.
Aux. 81dg.
ORE-PR0028 Gas 85ci n.
(a) Filters pipe 1RE-PR021A Particulate 8Scin.
tunnel EL 1RE-PR0218 Gas 8$cin.
9.
1RE-PR027A Particulate 8$cin.
383' Units 1 1RE-PR021C 1
YScia.
Gland Steam Exhaust 2RE-PR027A Particulate 85 cia.
2 and 2 1RE-PR0278 Gas 85cin.
2RE-PR0278 Gas 85cin.
TI'I"*
(b) Pipe Tunnels 2
of Unit 1 at 2RE-PR027C 1
T3CI"*
2 i
EL 394* 6*
I
- 10. Laundry Room Exhaust ORE-PR015 Particulate 85cin.
l (c) Spray additive tank area of
- 11. Aux. 81dg. Plant ORE-PR021A Particulate 8$ci n.
Unit 1 Areas ORE-PR022A Particulate 85ct s.
ORE-PR0218
~ Gas 85ct n.
(d) Piping Penetration areas at EL 364' ORE-PR0228 Gas 85cin.
383* and 401' of Unit 1 ORE-PR021C 1
ISCI "*
2 ORE PR021C 1
TICI"*
2 7
2.
Aux. Bldg.
(b). (c) and (d) above 2RE-PR021A Paeticulate 85ctn.
B.
Liquid Y ctn.
S only for Unit 2 2RE-PR0218 Gas 85 :1n.
1.
Steen Generator Bloudoun 1RE-PR008 Gross y l
YScin.
Preft1ter 2RE-PR006 Gross y yScin.
2 3.
Fuel Handitng B1dg. Exhaust ORE-PR024A Particulate 8Scin.
2.
Steam Generator ORE-PR016 Gross Y YSctn.
ORE-PR0248 Gas 85cin.
After filter ORE-PRO 17 Gross Y YSci n.
l ORE-PR024C 1
YScin.
ORE-PR018 Gross Y YScin.
2 ORE-PR019 Gross Y YScin.
l 4.
Radmaste 81dg. Venttiation ORE-PR026A Particulate B Sci n.
Exhaus t ORE-PR0268 Gas 8Scin.
3.
Reactor Containannt Fan 1RE-PR002 Gross Y YScin.
ORE-PR026C 1
YScin.
Coolers Essential Service 2RE-PR002 Gross Y 15cin.
2 Water Outlets 5.
Laboratory Fume Hood Exhaust ORE-PR003A Particulate SScin.
1RE-PR003 Gross Y YScia.
ORE-PR0038 Gas 8 Sci n.
2RE-PR003 bros s Y Y5cin.
ORE-PR003C 1
TICI"*
2 4.
Component Cooling Water 0:tE-PR009 Gross Y YScin.
6.
Miscellaneous Tank Ftiter ORE-PR025A Particulate 85cin.
Heat Exchanger Water 1RE-PR009 Gross Y YScin.
Vent Exhaust ORE-PR0258 Gas BSctn.
Outlet 2RE-PR009 Gross Y Y5 cia.
ORE-PR025C 1
TSCI"*
2 Y cin.
S 5.
Baron Thermal Regeneration 1RE-PR007 Grossy 7.
Containment Purge IRE-PR001A Particulate 85cin.
Chiller Surge Tank Return 2RE-PR007 Gross Y v5ci a.
2RE-PR001A Particulate SSctn.
1RE-PR0018 Gas 85cin.
2RE-PR0018 Gas 8$cin.
IRE PR001C 1
Y5cin.
2 2RE-PR001C 1
IS'1"*
2
T,
~
1
- O Table 11.5-1 (continued)
Monitor Monitor Monitor No.
Monitoring Type 6.
Radwaste Evaporator ORE-PR006 Gross Y Y Sci n.
Condensate Return ORE-PR007 Gross Y Y Sci n.
ORE-PR008 Gross Y Y Sci n.
Airborne Effluents 1.
Aux. Bldg. Vent Stacks 1RE-PR028A Particulate BSci n.
2RE-PR028A Particulate SSci n.
1RE-PR028B Gas BSci n.
2RE-PR028B Gas BScin.
YSci n.
2 2RE-PR028C 1
YSci n.
2 Liquid Effluents Gross Y YSci n.
1.
Liquid Radwaste Effluent ORE-PR001 2.
Station Blowdown ORE-PR010 Gross Y YSci n.
4 4