ML20050D050
| ML20050D050 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/29/1982 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Tauber H DETROIT EDISON CO. |
| References | |
| NUDOCS 8204120008 | |
| Download: ML20050D050 (16) | |
Text
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. DISTRIBUTION:
1 Docket File-bcc:
TERA LB#1 Rdg.
PDR JYoungblood LPDR MRushbrook NSIC MAR 2 9 lE LKintner TIC DEisenhut ACRS (16)
SHanauer Docket 140.: 50-J41 RMattson HThompson e
g RVollmer N
Hr. Harry Tauber RHartfield, MPA s' 6gef'g s
Vice President 0 ELD Engineering & Construction 0IE 2
7 Detroit Edison Company 9,
@%g Gj 2000 Second Avenue g
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Detroit, tlichigan 4822b g
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Dear Mr. Tauber:
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Subject:
Radwaste llanagement Systems Hodifications for Fermi 2 One of the open iteias in Supplement tio.1 to the Fenni 2 Safety Evaluation Report is the review of the modification to radwaste managenent systeras submitted in FSAR Amendment No. 38.
As a result of this review of the racotfica radwaste systens the staff has developea the enclosed requests for additional information. The requestea intonaation was discussed with your representatives.
Please auend your application to provide the additional infonaation that is requested in the enclosure. Our review schedule is based on the assumption that the additional information will be available for our review by April 16, 1902.
If you wish clarification of the requests or if you cannot meet these dates, please telephone the Licensing Project Hanager, L. Kintner, within 7 aays after receipt of this letter.
sincerely, Mginal signea byi L J. Youngblood.
B. J. Youngblood, Chief Licensing Branch tio.1 Division of Licensing lk
Enclosures:
Request for Additional infonaation "The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents :
cc w/encls.: See next pdSe therefore, 000 clearance is not required under P.L.96-511. "
8204120008 820329 PDR ADOCK 05000341 A
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pdRC FORM 318 (10-80) tenCM 024o OFFICIAL RECORD COPY usam mi-.mma o
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Mr. Harry Tauber Vice President Engineering & Construction
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Detroit Edison Company 2000 Second Avenue Detroit, Michigan '48226 cc:
Mr. Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.
Washington, D. C.
20036
^
Peter A. Marquardt, Esq.
Co-Counsel lhe Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226
'Mr. William J. Farner Project Manager - Fermi 2 The Detroit Edison Company 2000 Second' Avenue Detroit, Michigan 48226 s
Mr. Larry E. Schuerman-Detroit Edison Company 3331 West Big Beaver Road Troy, Michigan 48084 David E. Howell, Esq.
3239 Woodward Avenue Berkley, Michigan 48072 Mr. Bruce Little U. S. Nuclear Regulatory Commission Resident Inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Dr. Wayne Jens Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 W- -
Mr. James G. Keppler Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 i
1
't ENCLOSURE i
REQUEST FOR ADDITIONAL INFORMATION IN THE SAFETY REVIEW ENRICO FERMI ATOMIC POWER PLANT UNIT 2 DOCKET NO. 50-341 Requests by the following branches in NRC are included in this enclosure.
Requests and pages are numbered sequentially with respect to previously transmitted requests.
e Branch Page No.
Effluent Treatment Systems Branch 010-5 through.010-16 Chemical Engineering Branch -
021-28 Fire Protection Review e-e G
9 e
4 O
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010-5 Request for Additional Information Enrico Fermi Atomic Power Plant, Unit No. 2 010.0 EFFLUENT TREATMENT SYSTEMS BRANCH 010.6 FSAR Amendment 38 contains completely revised descriptions of the liquid waste management system and the solid waste management system, as well as changes in the data needed for the radioactive source term calculations and changes in the applicant's -estimated annual releases from liquid effluents. We have reviewed the revised FSAR and f'ind that we need the following additional information to continue our review.
s 010.6.1 Section 11.2, " Liquid Waste Management System", (LWMS) of the NRC Standard Review Plan, NUREG-0800, provides that the staff review the system piping and instrumentation diagrams and system process flow diagrams submitted by the applicant to determine all sources, of liquid input volumes, the points of collection of liquid waste, the flow paths of liquids through the system including all by-passes, the treatment provided, and the points of release of liquid effluents to the environment. The FSAR, as amended (Amendment No. 38), provides no information relevant to the staff's evaluation of liquid wastes from any laundries and personnel decontamination facilities that may be located at the plant. Provide the relevant information described above concerning liquid wastes from laundries and personnel decontamination facilities.
i i
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010-6 I,
010.6.2 HRC Regulatory Guide 1.143, Revision 1, October 1979, entitled
" Design Guidance for Radioactive Waste Management Systems, Struc-tures, 'and Components Installed in Light-Water-Conled Nuclear Power Plants,"' states that "The systems'(handling radioactive materials in liquids) should be designed and tested to requirements set forth in the codes and standards listed in Table 1 supplemented by regulatory positions 1.1.2 and 4 of this guide". Table 11.2-5, i
"Radwaste Equipment Design Requirements", of the FSAR contains several deviations from Table 1.
Provide justification or s
clarification for the following infonnation in Table 11.2-5, which deviates from Regualtory Guide 1.143.
(a) Table 11.2-5 of the FSAR prescribes for the design, fabrica-tion, inspection and testing of atespheric or 0-15 psig tanks ASME Code Section III, Class 3, or API 620 or 650, or AWWA D-100. Whereas, Table 1 prescribes for the design, far rication, inspection and testing of atmospheric tanks the ASME. Code Section III, Class 3, or API 650, or AWWA D-100; and, separately, for 0-15 psig tanks the ASME Code Section III, Class 3, or API 620.
(b) Table 1 does not provide for the use of ASTM for atmospheric or 0-15 psig tank materials and manufacturer's standards for welder qu'alification and procedures for pumps as are shown in Table 11.2-5 of the FSAR.
a
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. y 010.6.3 The FSAR, as amended (Amendment No. 38), states that "The volume
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reduction and solidification (VRS) system (is) designed by the i
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Werner-Pfleiderer Corporation" and identifies the subsystems
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which comprise the VRS system. The FSAR also states that "the VRS
)
system is described in detail in a topical report (WPC-VRS-1) prepared for the NRC in November 1976". The FSAR also provides information on the VRS system. The topical report has been amended
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f twice since 1976.
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Provide clarification in the FSAR of the following areas:
+;gaa:a (a) The reference to the topical report should. be clarified-to indicate whether it includes Amendment I to[the
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topical report, containing data provided in response to the NRC request for additional information on March 23,
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,1 1977, and to Amendment II, containing data provided in
"??f43Cy2 response for additional information on November 18, 1977.
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(b)
It should be stated whether the extruder / evaporator is a VRS-T120 unit or another unit as described in the topical j:c 4,
t..
report and amendments.
The Radwaste Systems Process Flow Diagram, Figure 11.2-2, (c) of the FSAR indicates that the occinal operating mode flow Yh[.)-f[f rates for four separate input streams to the extruder /
>."-.o evaporator are as follows:
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010-8 l.
010.6.3 (c) 1.
concentrate feed to extruder, 0.58 gpm (35 gph);
(cont.)
ii.
centrifuge extruder feed, for bead and powdered j
resin, 1.4 gpm (84 gph);
iii. powdered resin slurry fed, 0.56 gpm (34 gph);;and, iv.
slurry feed tank discharge, bead resins, 0.63 gpm (38 gph).
In Amendment I of the topical report it is stated that "The evaporative capacity for a VRS-T120 is rated at a minimum of 1201/hr (approximately 32 gph) for all feed streams. This x
rated capacity ~is a guaranteed capacity which has been proven to be very conservative in recent testing".
It should'be clarified either that the nominal operating mode flow rates are not in excess of the guaranteed capacity, or what measures will be taken in the event that the extruder / evaporator is unable to perform satisfactorily at the nominal operating mode flow rates indicated to be in excess of the guaranteed capaci ty.
(d) The NRR staff evaiuation of the topical report was transmitted to Werner &'Pfleiderer on April 12, 1978.
It is stated in the Regulatory Position of the staff's evaluation that "Any application incorporating this report by reference should include all' deviations from this report". To the extent that 4
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. 010-9 010.6.3 the FSAR does not presently identify these deviations, they (cont.)
should be so identified.
If there are no deviations it
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should be so stated.
010.6.4 Branch Technical Position (BTP) ETSB 11-3, " Design Guidance for Solid Radioactive Waste Management Systems Installed in Light-Water-Cooled Nuclear Power Reactor Plants", attached to Section 11.4,
" Solid Waste Management Systems", of the NRC Standard Review Plan states that " Activated charcoal, HEPA filters, and other dry wastes which do not normally require solidification processing should be treated as radioactively contaminated solids and packaged' for dis-posal in accordance with applicable Federal regulations". The-FSAR, as amended (Amendment No. 38), provides no information specifically regarding the treatment and disposal of activated charcoal and HEPA filters.
Describe the methods to be employed for the treatment and disposal of activated charcoal and HEPA filters.
010.6.5 BTP ETSB 11-3 states that " Spent cartridge filter elements may be packaged in a shielded container with a suitable absorber such as vermiculite, although it would be desirable to solidify the elements in a suitable binder." The FSAR, as amended (Amendment No. 38),
provides no information specifically regarding the treatment and l
l disposal of spent cartridge filters.
l
010-10 010.6.5 Describe the methods to be employed for the treatment and disposal l
(cont.)
of spent cartridge filters.
010.6.6 BTP ETSB 11-3, states that " Tanks accumulating spent resins from reactor water. purification systems should be capable of accom-modating at least 60' days waste generation at normal generation rates. Tanks accumulating spent resins from other sources and tanks accumulating filter sludges should be capable of accommodating at least 30 dhys waste generation at normal generation rates".
According to the normal generation rates and tank capac'ities given in the FSAR as amended (Amendment No. 38), these tanks are capable
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of accommodating only about 15 days of waste generation. No -.
information is given to provide the basis for determining that this is adequate in the light of the needs for allowing time for short-lived radionuciides to decay prior to processing, allowing time for process maintenance, or other factors.
Provide information for determining the acceptability of the capacities of these tanks for accomnodating waste that is generated.
010.6.7 BTP ETSB 11-3 provides supplementary guidance regarding the design and use of portable solidification and/or dewatering system.
Figure 11.2-2 "Radwaste System Process Flow Diagram" of the FSAR as amended ( Amendment No. 38), contains blocks labeled "FROM 1
I
010-11
. 010.6.7 (cont.)
PORTABLE SOLIDIFICATION SYSTEM" and "T0 PORTABLE S L
SYSTEH".
No additional information is provided in the FSAR on
.c.7'
,y these systems.
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Provide information regarding the portable solidification system in relation to the relevant factors addressed in the BTP.
7f.t i$1 010.6.8 BTP ETSB 11-3 states that " Solidification agents should be stored in low radiation areas, generally less than 2.5 mr/hr, with Ultj provisions for sampling". The FSAR as amended (Amendment No. 38),
p?gj does not provide sufficient information to determine 'if the radiation levels at the locations where solidification agents are stored is less than 2.5 mr/hr.
y Provide the information identified above.
010.6.9 NRC Standard Review Plan 11.4, " Solid Waste Management System",
l4 states that the staff " compares equipment layout, design features,
.4 and mode of operation of the solid waste system to the guidelines of Regulatory Guide 1.143 and BTP 11-3".
The FSAR as amended
( Amendment No. 38), states that " Figure 12.1-3 shows the general layout of this (volume reduction and solidification system) 5; equipment".
However, of the 10 subsystems comprising the'VRS system, only the extruder / evaporator is identified in the figure.
Information on the gen'eral layout of the entire system is not otherwise provided in the FSAR.
t
010-12' 010.6.9 Provide complete infomation on the general layout of the VRS l
(cont.)
i system in a figure such as Figure 12.1-3 of the FSAR.
W 010.6.10~ Additional infomation is needed regarding the solid waste manage-99y'I ment system as described below.-
., fl (a) Section 11.4, " Solid Waste Management Systems" (SWMS), of the
-.v NRC Standard Review Plan, NUREG-0800 provides specific criteria iaQ,6 /-; -
j necessary to meet the relevant requirements of the Commission's regulations.
Included are the following:
i.
The system design parameters are based on radionuclide M
concentrations and volumes consistent with reactor operating experience for similar designs';-
ii.
All liquid wet wastes will be solidified in accordance with 'a process control program prior to shipment off-site or there will be provisions to verify the absence of free liquid in each container and to reprocess containers in which free liquid is detected in accordance with BTP ETSB 11-3.
The FSAR, as amended (Amendment No. 38), provides:
(1) no infomation relevant to the radionuclide content and volumes of dry solid waste; (2) inconsistent infomation in the annual total volumes of solidified wet solid wastes to be shipped (see FSAR Table 11.5-2 and Figure 11.2-2);
4
t 010-13 l
010.6.10 (3) no information on the normal annual total activity of (cont.)
solidified wet solid wastes to be shipped; and (4) no commitment to conformance with a process control plan or provisions to verify the absence of free _ water and to reprocess containers in which free water is
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detected.
Provide the information identified in items (1) through (4) above.
(b) Reactor operating experience with similar designs (BWRs with C
powdered resin condensate polishing systems), but using solidification agents other than asphalt suggests, 'for,.
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Fermi 2 operating at an 80% capacity factor, that an average of about 20,000 ft3 (2,300 Ci) of solidified wet waste would be shipped annually and about 16,000 ft (less than 5 Ci) of
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dry waste would be shipped annually.
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Provide an explanation for apparent inconsistencies between the Fermi 2 solid waste volume and activities and those expected in consideration of reactor operating experience with similar designs.
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@M-Ed
. 010.6.11 NUREG-0473, Revision 2, " Radiological Effluent Technical Specifi-cations for BWRs", February 1,1980, provides in Table 3.3.7.11-1 that radioactive liquid effluent monitoring instrumentation include a discharge canal flow rate measurement device and tank level indicating devices for tanks containing radiaoctive fluids outside plant buildings. The FSAR, as amended (Amendment No. 38),
1 provides no information concerning these devices.
. Describe the instrumentation identified above that will be
)
employed for liquid radioactive effluent monitoring. ' If this instrumentation deviates from the provisions of NUREG-0473, provide justification for such deviations.
NUREG-0473, Revision 2, " Radiological Effluent Technical Specifi-010.6.12 cations for 'BWRs", February 1,1980, provides in Table 3.3.7.12-1 that radioactive gaseous effluent monitoring instrumentation include the following:
(a) Noble gas activity monitor providing alann and automatic
.tennination of release for the main condenser offgas treatment system effluent monitoring system.
(b) Effluent system flow rate monitors for the reactor building ventilation / purge monitoring system, main stack monitoring system, turbine building ventilation monitoring system, auxiliary building ventilation monitoring system, and radwaste area ventilation monitoring system).
,-wem-,
010-15 (c)' Noble gas activity monitor, iodine sampler, particulate 010.6.12 j
(cont.)
sampler and sampler flow rate monitor for the reactor j
building ventilation / purge monitoring system.
The FSAR, as amended (Amendment No. 38), provides no infomation concerning these devices.
Provide a description of the instrumentation identified above that If will be employed for gaseous radioactive effluent monitoring.
this instrumentation deviates from the provisions of NUREG-0473, s
provide justification for such deviations.
NUREG-0473, Revision 2, " Radiological Effluent Technical Specifi-010.6.13
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cations for BWRs", February 1,1980, provides in Table 4.11-2,
- Radioactive Gaseous Waste Sampling and Analysis Program", that the lower limit of detection of principal gamma emitters (I-131,
-11 uCi/ml and that the others) in particulate samples is 1 x 10 i
-12 uCi/ml. The FSAR lower limit of detection of I-131 is 1 x 10 as amended ( Amendment No. 38) states, in Table 11.4-5, " Radio-logical Analysis Summary of Gaseous Process Samples", that the of f-gas vent sample analysis for the gamma spectrum will have a
-10 3 and the off-gas vent sample analysis
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sensitivity of 10 uCi/cm for I-131 on particulate filter will have a sensitivity of
-10 3
10 uti/cm,
010-16.
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010.6.13 Provide clarification of these apparent inconsistencies and cont.)
justification of any deviations from the provisions of NUREG-0473.
010.6.14 Provide the Fenni 2 Offsite Dose Calculation Manual that will be referenced in the plant Technical Specifications.
I G
9 O
' 021-28
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021.0 CHEMICAL ENGINEERING BRANCH - FIRE PROTECTION SECTION:
021.34 By'FSAR Amendment 38, the applicant stated it will install a radwaste volume reduction and solidification (VRS) system manufactured by Werner-Pfleiderer Corporation (WPC). The applicant has verbally provided the following information regarding fire protection aspects of the system.
(1) The radwaste system interface with the remainder of the plant meets the fire protection requirements of BTP-CMEB 9.5-1.
(2) Three hour fire rated barriers, including doors and penetration seals, separate the radwaste system from the rest of the plant.
- s (3) Automatic sprinkler protection in conformance with NFPA Standar.d 13 has been provided for the radwaste system.
(4) A dike has been constructed around the radwa'ste asphalt storage tank and it is sized to contain the entire contents of the tank.
(5) No safety related systems are located in the area.
4 (6)
Floor drains have been so located as to prevent flammable liquid spills from affecting other plant areas.
(7) Automatic fire detectors are provided for early warning.
(8) The ventilation system for the radwaste area can be separated from other plant areas.
Please amend the FSAR.to incorporate the above verbal s'tatements.
.