ML20073P623

Rev 2 to Process Control Program,Packaging of Low Level Radwastes

ML20073P623
Person / Time
Site:	Summer
Issue date:	04/15/1983
From:	Browne M, Guy G SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20073P622	List: ML20073P620 ML20073P623
References
PROC-830415, NUDOCS 8304270005
Download: ML20073P623 (29)

Text

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SOUTH CAROLINA ELECTRIC AND GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATION PROCESS CONTROL PROGRAM PACKAGING OF LOW-LEVEL RADI0 ACTIVE WASTES DATE OF ORIGINAL ISSUE:

DECEMBER 23, 1981 PREPARED BY: W ,e c nica port Eng eer APPROVED BY: -. _ o Neivin N. mraw1TU, Assistant Manager Technical Support REV' EWE) BY 3SRC REVISION DATE APPROVED

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it '. 0 -SCOPE-1.1 Purpose

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The purpose'of this Process Control Program forfthe Virgil'C.J Summer NuclearL Station is to .cstablish a set of process parameters.'which provide reasonable assurance thatthe. packaged : radioactive wastes meet..

applicable Department Jof Transportation (DOT), Nuclear

- Regulatory Commission (NRC), and South Carolina State regulations for shipment and offsite- burial at: an .

approved site. Additionally, reasonable assurance 'is provided that'the. acceptance criteria of said4 burial facility-are met.

1.2 Applicability This Process Control Program shall be used by alli personnel for the packaging'of low level radioactive wastes. This program includes Chem-Nuclear Systems-Incorporated (CNSI) personnel operating CNSI supplied equipment.

2.0 References 2.1 ~ Virgil C. Summer Nuclear Station Final Safety Analysis Report,' Chapter 10 and 11, FSAR Questions 321.17, through 321.23 2.2 ~SCE&G. Corporate ALARA Plan.

23 Virgil C. Summer Nuclear Station Technical Specification 3/4.11 3 2.4 Virgil C. Summer Nuclear Station Quality Assurance i Program.-

25 CNSI Quality Assurance' Program, QA-AD-001, and CNSI Process Control Program,11n 4313-01354-01.

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2 .' 6 CNSI Operating Procedures for Cement Golidification and' Dewatering Units, as applicable SD-0P-036 and F0-0P-003 27 CNSI Topical Report, 4313-01354-01.

2.8 NUREG 0472, Radiological Effluent Technical Specifications for PWR.

l 29 -Branch' Technical Position-ESTB 11-3, Design Guidance for- Solid Radioactive Waste Management Systems Insta11ed'in Light-Water-Cooled Nuclear Power Reactor Plants.

2.10 ANSI 199, -Liquid -Radioactive Waste Processing Systems -

for Pressurized Water Reactor Plants.

2.11 NRC Regulatory Guide 1.143, Design Guides for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Cooled Nuclear Power

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Plants.

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2.12 SRP 11.4 Rev. 2 July, 1981 " Solid Waste Management Systems".

2.13 100FR50, Appendix A. .

30 System, Description 31 Process Description The Waste Processing System is designed to dewater and/or solidify radioactive wastes, evaporator bottoms, ion exchange resin slurries and sludges. The process utilizes a- CNSI skid-mounted portable cement solidification unit and dewatering equipment.

The cement process makes use of the readil available Portland cements and hydrated lime (Ca(OH) ) to solidify liquid wastes. The process is in tiated by transferring liquid waste into the CNSI disposable liner. The waste is then conditioned by adding conditioning chemicals as required. (Conditioning chemicals may also be preloaded into the liner). With continuous agitation provided by the installed mixer blades, cement is added to develop a thick paste like slurry which will solidify to~a hard, water-free end product.

I 32 . Process Parameters .

Cement undergoes four separate ~ reactions during its curing time which permanently combines cement, water and a variety of ions found in waste streams to form a stable, solid concrete end product. Certain chemicals and metallic ions present in the waste act' as

. accelerators or retardants to these reactions. By pretreating .the vaste with chemicals designed to limit ,

or neutralize these effects, a controlled, accept able cure time can be achieved and the waste-to-additive ratio .will be significantly improved. Each of the reactions is exothermic and by controlling the speed of reaction and minimizing the-. total cement addition by the use of certain additives, the heat developed by large volume solidifications will also be minimized.

The sample verification procedure (Section 5 0) will serve to verify the exact pretreatment required to achieve the optimum waste-to-additive ratio. The amount of additives and cement to be used for sample and full scale solidifications are provided by Exhibit 2.

-3 3' Waste Processing Unit Description 331 The waste processing unit contains all piping, support, control and monitoring equipment necessary to dewater and/or. solidify radioactive waste (Reference 2.6).

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332 The Waste Processing Unit is composed of several processing subsystems, each controlling i a specific function of the process. These subsystems include waste transfer, chemical addition, cement conveyor, vent, and dewater systems. Control functions for the unit are incorporated into the solidification control panel.

3 3 3. Most of the waste processing unit components are arranged on skids to provide flexibility of operations. The cement conveyor, control panel, pump skid, hydraulic skid and fillhead contain most of the major elements of the mobile unit.

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334 A closed-circuit television system is an integral part of the unit and allows the operator to ^ monitor. the solidification or dewaterin6 Process.

34 System Operation 3 4.1 Before.beginning any waste processing,. Health

-Physics is to determine.the liner-type and-size, the cask type and -size, -the waste transfer requirements, and the process-operation requirements..

-3 4.2 Resin Dewatering-Primary spent resins and steam generator blowdown resins may be dewatered by the portable unit as determined by Health Physics.

Whenever secondary side condensate polisher

- resins require disposal as solid radwaste as determined by. Health Physics, devatering equipment in the Turbine Building will be used in conjunction with the' Process Control

. Program. 'The Dewatering Completion Record

. (Exhibit .1)~ shall be used as the documentation

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l- data sheet.

3 4.2.1 Establish or verify that- the liner is in a level position (visual determination).

3 4.2.2 Connect the euction hose to the. outlet-L connection on the liner and to the suction of the dewatering pump.

3423 Connect one end of the outlet hose to i

the discharge of the dewater pump and i direct the other end to the dewater

! return connection.

3 4 2.4 Connect the service air hose to the g

service air supply and the dewatering i Pump.

3425 Establish service air to the pump.

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A 3 4 2.6 Adjust the pump air supply valve to establish a minimum pumping rate of 2 strokes.per second. Enter the time in

the operating log and the Dewatering Completion Record.

3 4 2.7 Continue pumping for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> then shut off the pump. Record shut-off time in the operating log'and' the Dewatering Completion Record.

3 4.2.8; Let the vessel stand for a minimum of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

3 4.2 9 ' Repeat Steps 3 4 2 5 and 3 4.2.6.

Continue pumping for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> then shut off the pump. ~ Record shut-off time in the operating log and the Dewatering Completion Record.

3 4.2.10 Disconnect the suction hose from the outlet connection of the liner.

Complete the Dewatering Completion Record (Exhibit 1 ).

343 Cement Solidification As determined by Health Physics, liquid radwaste from the Chemical Drain Tank and the Waste Evaporator Concentrates Tank or other waste storage tanks, e.g. Spent Resin Storage tanks, will be solidified using the cement process.

3431 Before beginning any waste processing with the Cement Solidification Unit, the CNSI operator shall complete a successful sample verification in accordance with the Sample Verification Procedure of Section 5 0.

3432 The successful sample solidification parameters are included in the Solidification Information Sheets (Exhibit 2). These parameters are amplified for full scale solidification values, as appropriate.

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3 4 3,.3 Actual full scale-solidification shall -

then be conducted using the parameters calculated'in the CNSI Solidification i

Worksheet'II (Exhibit 4).

- 3.~ 4 3 41 Sequence of Operation - The conditioning chemicals may be preloaded into the liner or added to the waste while mixing. The addition of-chemicals or. waste usually may.be interrupted without ill effect. -The mixer- may also be secured during waste or. ~ chemical' addition with no effect ' on

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'the process, however, it must remain in operation during the cement addition. After cement addition, the mixer is secured and the process His complete.

3435 Mixer Speed - The mixer speed should be high. enough to allow complete mixing of waste conditioner and cement., Generally, the speed ~will be set at 40 RPM while adding conditioning chemicals and 40 to 75 RPM when starting cement addition.

The speed will be increased to 100 RPM after two-thirds of the cement has been added.

'3 4 3 6 Waste-to-Cement Ratio (by volume)

The normal waste-to-cement

/ conditioner ration (by volume) vill be approximately 2 to 1 up to 3 to 1 for evaporator concentrates and liquid wastes, and above 2 5 to 1 for resins, powdex and other solids.

If normal ratios are exceeded, cure time ~may-be delayed and the solidified product may have free-standing water i

on its surface.

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-3.~.3 4 7' Cure Time - Cure time will usually be 12 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and the temperatures-may rise during this. time to 200*F.

The liner should be ventilated until temperature starts decreasing

' indicating a-completed reaction.

4.0 REQUIREMENTS FOR SAMPLE VERIFICATION 41 General Precautions NOTE: IF DIFFICULTIES ARE ENCOUNTERED WITH ANY PART OF THIS VERIFICATION PROCEDURE OR UNEXPECTED RESULTS ARE-0BTAINED, CONTACT HEALTH PHYSICS.

4.1.1 The chemicals and cement used are considered .

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non-toxic and safe to handle, however, care should be used to avoid breathing dust.- If a liquid caustic is used for.special applications,. follow the safety precautions.

42 Radiological Precautions 4.2.1 The operator shall be subject. to the applicable Health Physics and safety precautions of the Virgil C.. Summer Nuclear Station.

4.2.2' Laboratory gloves, face shield and an apron shall be worn while handling, collecting and testing of all samples.

423 The operator shall establish radiologically clean and contaminated zones in'the sample process area to prevent the possible spread of contamination.

43 Prerequisitica 431 Waste Recirculation 4 3 1.1 Due to the importance of obtaining a representative sample for use in the verification procedure, the operators .

l shall confirm that the contents of the waste storage tank have either been recirculated for a minimum of three volume turnovers or are adequately sixed to achieve a homogeneous mixture.

r 4 3 1.2 Any~ number of mechanical operations of

- the' waste storage tank may negate the ~ u effects of previous recirculation / l agitation period. These operations '

would include the following:

4 3 1.2.1 Introduction of additional l weste into the storage tank i after recirculation has '

commenced.-

4 3 1.2.2 Securing of recirculation, ,

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while drawing the I verification sample. l 1

4 3 1.2 3 Shifting from a i recirculation mode to a transfer mode.

4313 JIf any of the situations listed above occur, it will be necessary to repeat the recirculation process and satple verification procedure of Section 5 0 in. order to re-establish the solidification' process parameters.

432 Health Physics / Chemistry ~ shall identify the waste properties as far as practicable, i.e.;

oil content,-. density, type, estimated activity.

Waste containing oil above one percent by volume shall not be solidified by this PCP.

433 Resins that are to be dewatered only are sampled to determine activity. The sample count is to be performed by Health Physics.

434 The remainder of this sample verification program applies to-cement solidification.

4341 Equipment Equipment required for use during the sample verification procedure is listed in Table 1. The table indicates the minimum quantity required to begin a verification procedure.

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The_ operator'shall ensure that all' necessary equipment- is available or adequate substitutes- are available'.

The operator shall ensure that additives. received comply with the chemical composition necessary for-this process.

4 3 4.2 Sample Acceptance Criteria - In order to ensure acceptable solidification has occurred, the operator shall confirm that all acceptance criteria are met as follows:

4 3 4 2,1 Visual inspection of the mixture after cement addition to confirm that the mixture is homogeneous .

with no free water on the surface.

l 4 3 4 2.2 Visual inspection of the end product af ter hardening to indicate a uniform, liquid free, free standing monolith.

l 43423 The end product resists i

penetration when probed vith a pencil size probe.

CAUTION: The concrete Matrix must be less than 175'F and indicate a steady, positive l .~ decreasing temperature prior to sealing. It must also be water free. It may be desirable to add a small amount of dry cement to

. absorb any condensate liquid on the billet l surface and container l walls. The liner shall not l be sealed within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of mixing completion.

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4343 Requirements for Sample Verification 43431 Verify that. all material listed in Table 1 is available and ready to use

-in the area for-solidification sampling.

43432 Use the CNSI Solidification Worksheet I (Exhibit 3) for all sample solidifications.

,, '43433 Sample Requirements 434331 A sample shall be solidified prior to full scale solidification of waste. If there is no change in the-chemical composition of the waste as verified by Health Physics,-test results and-full scale l

solidifications will be conducted l prior to the l

tenth batch l solidified --

from the same source of waste.

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434332 The operator shall ensure that the sample is representative-(i.e.;

tharoughly mixed) and that the sampleiline is properly purged prior

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to drawing the PCP sample.

NOTE: If the initial test specimen from a tank fails to' verify SOLIDIFICATION, collect and test s

representative samples from that tank until three consecutive test specimens demonstrate SOLIDIFICATION.

50 Sample Verification 51 Samples may be obtained at the Chemical Drain Tank, &

the. Waste Evaporator Concentrates Tank. Spent resin sampling is accomplished at the sample point on the

' resin transfer line.

52 Forfcement solidificatlon, calculate & record the available information on Exhibit 3 for all vaste type-sample verifications.

NOTE: WASTE SOLIDIFIED ON A-SMALL SCALE WILL CURE MUCH SLOWER BECAUSE-0F THE EXCESSIVE SURFACE TO VOLUME RATIO FOR HEAT TRANSFER. . SAMPLE STORAGE IN AN APPROVED CONSTANT TEMPERATURE OVEN WILL ENABIE A MORE MEANINGFUL EVALUATION ON AN OVERNIGHT BASIS.

6.0 ADMINISTRATIVE PROCEDURES 6.1. Maintenance of Records

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s .r-6.1.1 Dewatering The-operator shall confirm that the completed

' Dewatering Completion Record is accurate and in.

compliance with.the dewatering procedure. The operator shall retain original and forward one copy to Health Physics.

6.1.2. Cement Solidification

.The: operator shall retain originals and forward

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one copy of the completed sample verification forms to Health Physics.

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TABLE 1 EQUIPMENT REQUIRED FOR TESTING SAMPLES 250 ML Plastic Beakers with Lids 6 600-1000 ML containers with Lids 6 Chemicals to be Stirring Devicca (5) used should be Pipettes (2) taken from the Pipettor full scale 0-212*F Thermometer -

solidification pH Paper: Wide Range (1.0 to 11.0) chemicals listed Narrow Range _(8.0 to 12.0) on the respective-0-600 or 0-1000 gm Triple Beam Balance figure for each If Liquid Caustic is Used: waste form.

Hydrometer, Range 1.000-1.200 50 ML Buret (2)

Ring Stand Buret Clamp (2)

Marking Pen-Sample Heating Oven, Thermostatically Contro11ed' from 100*F to 180*F.

Kitchen Strainer, 1/16" Openings Graduated Cylinders, 250 m1'(2) 1 l

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EXHIBIT 1 Virgil C. Summer Nuclear Station-DEWATERING COMPLETION RECORD

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Vessel Designation: . Vessel Serial':

Proc. Step Description Date Time Operator I.4 2.6 Start dewatering pump .

3 4.2 7 Secure dewatering pump-Total pumping time:

(Must be > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) _

3 4.2.8 Let vessel stand for > 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 3 4.2 9 Start' dewatering pump Secure dewatering pump Total pumping time:

(Must be > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) i.

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-m q EXHIBIT 2 SOLIDIFICATION INFORMATION SHEETS A. PCP SOLIDIFICATION OF BORIC ACID CONCENTRATES (PWR WASTES) 1.0 Sample Verification NOTE: THE CHEMICAL ADDITIVES USED FOR IOP PREPARATION SHOULD HE THOSE ACTUALLY USED IN FULL SCALE SOLIDIFICATION AND SH0lJLD BE STORED IN CAPPED CONTAINERS.

- 1.1 From the waste analysis supplied by the utility, determine the appropriate additives from the following chart and enter the amounts on CNSI Solidifcation Worksheet I. Use minin2m amounts of cement and lime in accord with waste propertis and past experience.

CHART 1-Boron Content Boric Acid Calcium *CNSI

• Sodium.

Of Waste Equivalent Cement Lime Chloride Moderator droxide (PPM) (W Weigit) . (gms) (gm) (gm) S-4 (sm) %(50% Solu) 0- 3,500 0-2% 190-240 10-20 30 .10 2 5 r1**

3,500- 7,000 2-4% 180-230 20-30 30 10 2 5 m1**

7,000-10,500 4-6% 170-220 30-40 30 10 2 5 m1**

10,500-14,006 6-e% . 1ro-210 40-50 30 10 2 5 m1**

14,000-17,500 8-10% - 150-200 45-60 30 10 2 5 m1**

17,500-21,000+ 10-12%& 145-190 50-70 30 to 2 5 m1**-

• Typical Amounts Or As Required, If Arar, By Test Results. **0r 5 ml of 25% '

Solu.

1.2 Notify Health Plysics that preparations for verification testing have been completed and request that a sample be taken.

13 Freshly screen sufficient lime and cement in separate containers to avoid undisperced lumping in the samples.

1.4 Add calcium chloride, CNSI Moderator S-4, and lime (as indicated in Chart 1) to a 600-1000 ml container.

'15 Ensure that the vaste sample is uniform _by heating to l 140*F or more if necessary and then add'200 ml- to I each container. Mix thoroughly using . wide blade spatula and then check the pH of each sample with narrow range _ paper and record results on CNSI Solidification.Worksheet I. The pH at this point should be- at least 10 5 Continue. mixing and retesting.if the pH is low, and add more lime if necessary. Record weight of lime added on CNSI Solidification Worksheet I.

NOTE: LIME AND BORIC ACID WASTE IX) NOT REACT QUICKLY TOGETHER. BE SURE TO MIX THOROUGHLY FOR AT- '

~ LEAST 3 MINUTES-BEFORE DECIDING TO ADD ~MORE LIME. BASED UPON CONFIRMING THAT THE pH IS STILL LOW.

1.6 Add the appropriate amount of cement to the - _

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container (s) while continuing mixing with spatula.

Blend mixture (s) thoroughly.

1.7 Using a pipet, add _the sodium hydroxide solution, if required, and mix thoroughly.  !

1.8 Transfer sample mixture (s) to 250 ml beaker (s). Fill to approximately 1/4" of the top.

19 Place lids securely on samples and immediately transfer .to oven controlled at 135' + 5'F. Then cure for 6-24 hours, according to experience.

1.10 Remove the samples from the oven, and allow to cool for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before removing the lid (s) and

. evaluating solidification results according to guidelines of Paragraph 4 3 4.2.

NOTE: OBTAINING A FIRM, DRY PCP PRODUCT AT 130*F WILL NORMALLY ASSURE THAT A TEST FORMUIA WILL PROVIDE A RAPID AND ACCEPTABLE FULL-SCALE SOLIDIFICATION WITH A CLEARLY MEASURABLE EX0 THERM. TO DEMONSTRATE ONLY THE EXPECTED FINAL PRODUCT HARDNESS. THE SEALED SAMPLE SHOULD BE CURED AT 170 + 5*F FOR 18-24 HOURS TO COMPLETE THE HARDENIRG REACTIONS.

NOTE: THE 2 HOUR COOLING PERIOD CAN BE DELETED IF EXPERIENCE WITH THIS PARTICULAR WASTE STREAM

. INDICATES THAT NO WATER IS STANDING ON THE SAMPLE AND IT MEETS THE REQUIREMENTS OF 4 3 4.2.

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t 2.0 FILL SCALE CAICUIATIONS (Boric Acid Concentrates) i 2.1 Determinethevolume'-(cubic' feet)ofwastetobe received in the liner. Refer to Table 2 for usable liner volumes and also consider past experience and allowable _ cask payloads.

2.2 'The amounts of cement and lime required are determined by using the information in the table below. The ratio of cement to lime varies according-to the analyzed level of boric acid in the waste.

Vaste Analysis Equivalent

• Weigh $ Of Lime *Wei t Of_ Cement PPM Boron Boric Acid Content Per Pt> Of Waste PerPtpOfWaste 0- 3,500 0-2% 4.0-8.0 Lbs. 59 4 - 75 0 Lbs.

3,500- 7,000 '2-4% 6.4-9.5 Lbs. 56.2 '- 71.8 Lbs.

7,00>10,500 4-6% 9 5-12 7 Lbs. 53 1 - 68 7 Lbe.

10,500-14,000 6-8% 12.7-15 8 Lbs. 50.0 - 65.6 Lbs.

14,000-17,500 8-10% ' 141-19 0 Lbs. 46.8 - 62.4 Lbs.

17,500-21,000+ 10-12%+ - 15 8-22.1 Lbs. 45 2 - 59 2 Lbs.

• Lime ani Cement factors selected are based on boron analysis, PCP results, and past experience.

23 Detarmine the full scale formula and level alarm settings by completing CNSI Solidification Worksheet II.

2.4 The volume of caustic required, if any, for full i

scale solidification is dependent on a number of variables, such as waste composition and ambient

! conditions. The maxirmim volume of caustic is 10 gallons of 25% concentration or 5 gallons of 50%

. concentration. These amounts are not to be exceeded without supervisor's approval.

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'B. PCP-Solidification Of-Particulate Wastes (Resin Beads,'

-Powdex And Diatomaceous Earth Slurries)

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1.0 Sample Verification NOTE: THE T CHEMICAL ' ADDITIVES USED FOR PCP PREPARATION' SHOULD BE. THOSE ACTUALLY USED IN FULL SCALE SOLIDIFICATION AND SHOULD BE STORED IN CAPPED CONTAINERS.

1.1 ~ Arrange with Health Physics to. assign a special . test area which contains adequate protection from the anticipated higher radiation levels'of bead resins..

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Notify Health . Physics that the preparations .for -

verification testing have'been completed and request that a waste sample be supplied.

13 Transfer 100 ml;of resin from the sample container to a'250 ml disposable . beaker and allow solids to settle. Typically, there will be a layer of water on-top of the resin. beads. Centrifuged : powdex will - show no separation of liquid.

NOTE: WHEN RADIAT10N ' LEVELS ARE EXCESSIVE, THE SAMPLE. AMOUNT IULY BE REDUCED TO AS LITTLE AS 25 ML. BE SURE TO REDUCE OTHER ADDITIVES BY THE SAME RATIO.

1.4 Measure and record on CNSI Solidification Worksheet I the waste pH using the wide range pH paper. Add lime (Ca (OH)2) in 2 gm increments until a pH of 10 5 to 11 5 is reached by a narrow (9-13) range pH paper.

Stir thoroughly after each addition of lime and add 3 more grams after the desired pH range is reached.

Record the total amount of lime added on CNSI Solification Worksheet I for particulate wastes. ,

Alternate Method: Where lime is not acceptable

. (i.e. ; cannot be added to the slurry) substitute 50 -

percent' sodium hydroxide solution for lime in Step 1.4 and add in one m1 increments until a pH of 11 to 11 5 is reached before proceeding with Steps 1 5 through 1.7 NOTE: LIME IS THE PREFERRED AGENT FOR PRE-TREATMENT

- 0F ION-EXCHANGE TYPE WASTES, SINCE IT IS MORE COMPATIBLE WITH CEMENT REACTIONS AND FORMS A MORE STABLE END PRODUCT.

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1.'5. Add cement slowly while stirring until a smooth homogeneous mix is obtained. The amount added for a 100 m1 waste. sample may be 80 to 150 gms depending on resin type, quantity of lime added and amcunt of water in the slurry. Record amount of cement added

.on the CNSI' Solidification Worksheet I.

1. 6 - Place ithe lid over the beaker and store the sealed mix in an oven controlled at 120-130 *F for 18-24 hours. Then allow sample to cool for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before removing lid and evaluating solidification.

1.7 Evaluate the sample using the- guidelines' of Paragraph 4342. If the camples does not meet the acceptance criteria, contact the CNSI Supervisor, Solidification Services for possible formula modifications.

2.0 FULL SCALE CALCULATIONS (BEAD-TYPE OR PARTICULATE WASTES) 2.1 Determine the volume of waste material to be received and the amount's of cement and lime or sodium hydroxide solution required by completing the CNSI Solidification Worksheet II for bead-type or particulate wastes. Reduce. the calculated amounts as necessary to comply with weight and radiation limitations imposed by waste activity and shielding requirements.

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C. PCP Solidification of Miscellaneous Aqueous Wastes (Not Representing Typical BWR OR PWR Concentrates) 1.0 . Sample Verification NOTE: THE CHEMICAL ADDITIVES USED FOR PCP TESTING JSHOULD BE THOSE ACTUALLY USED IN FULL SCALE SOLIDIFICATION AND SHOULD BE STORED IN CAPPED CONTAINERS.

1.1 Notify Health Physics that preparations for verification testing have been completed and that a sample is required.

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1.2 Measure out 200 ml of radwaste sample in a 600-1000 ml disposable container.

13 Add 120 to 140 grams of Portland Cement and mix well with spatula.

1.4 Add 80 to 100 grams of lime and mix well with spatula.

NOTE: ON A NEW WASTE SAMPLE, START WITH MINIMUM

_ QUANTITIES OF CEMENT OF LIME TO FORM A SM0OTH MIX NOT PRODUCING BICESSIVE BLEED LIQUID.

15 Transfer (pour) sample mixture into 250 ml plastic breaker, filling to within 1/4 inch of the top.

1 .- 6 Press lid tightly over sample container and store in an approved constant-temperature oven. The sealed sample should be held at 120-130*F for 18-24 hours.

NOTE: IT :8 NECESSARY TO HOLD SAMPLE MIXTURES AT ELEVATED TEMPERATURES TO SIMULATE SOLIDFICATION CONDITIONS OF FULL SCALE OPERATIONS.

1.7 Remove sample from oven and allow to cool for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before unsecling. Evaluate solidification using guidelines of Paragraph 4 3 4 2.

1.8 Contact the CNSI Supervisor, Solidification Services if the test sample containing maximum amounts of cement and lime still fails to meet solidfication requirements. A significant change in typical cement

. to lime ratio or reformulation with an approved additive tuy be necessary.

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2.0_ Full Scale Calculations 2.1 Determine the volume (cubic feet) of . waste to be received, referring to the ' table in Table 2. for usuable liner volumes.'

-2.2 Compelete the CNSI Solidification Worksheet.II for Miscellaneous Aqueous wastes to determine actual.

chemical requiremente.and level control settings.

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-EXHIBIT: 3

-CNSI SOLIDIFICATION WORKSHEET-I 1(PCP Solidification Of Particulate Wastes)J NOTE: -THIS INFORMATION IS CONSIDERED PROPRIETARY AND IS NOT TO BE RELEASED OR COPIED WITHOUT WRITTEN PERMISSION 0F-CHEM-NUCLEARESYSTEMS,- INC.

, Waste-Identification ~ Date: 0perator: Utility:

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Type.0f Waste: -(R'esins Beads, Powdex, Sludge)

Waste Activity: (Reported Curie Content) pH:' -(Reported By Utility).

Description:

(Color, Uniformity, : Free Liquid) -_

Saaple Preparation

'(a). Volume Of Waste (In 250 ml Container): ml (Notes ~(1&2)

NOTE 1: THE VOLUME OF. FLUIDIZED WASTE MUST BE CONTROLLED AS NEARLY AS 'POSSIBLE TO i'HE 100 ML MARK IN THE 250 ML TEST

, BEAKER, SINCE FULL-SCALE CALGULATIONS ARE NORMALLY FIGURES ON THIS: AMOUNT. REMOVE-WATER FROM, OR ADD WATER

. TO, THE WASTE ~SAMPIE RECEIVED AS NECESSARY S0 THAT A FLUID MATERIAL IS FORMED. NO MORE THAN ABOUT 1/16-1/8 INCH OF LIQUID SHOULD SEPARATE QUICKLY FROM.THE 100 ML TEST SAMPLE.

NOTE 2: IF THE RADIATION LEVEL OF THE WASTE PREVENTS USING A 100 ML SAMPLE, THE TEST .MAY BE RUN WITH LESS WASTE MATERIAL, BUT THE SOLIDIFICATION SUPERVISOR MUST BE CONTACTED FOR VERIFICATION OF THE FULL-SCALE FORMULA.

(b) pH Of Sample: (Tested By CNSI)

(c) Alkaline Agent To Be Added: (Indicate Lime or Caustic)

(d) pH Adjustment Summary Increment Amount pH After Mixing 1

2 3 _

4 _

. (e) Additional Lime gm

-(f) Total Lime, (d)+(e) gm (or total caustic, (d) ml)

-(g) Cement Added to Obtain Smooth, Uniform Mix em s

9 NOTE 3:'. DO NOT EXCEED ~100 GRAMS OFl CEMENT-PER 100 ML 0F WASTE UNLESS AN EARLIER TEST USING THE.SAME. WASTE SAMPLE

. INDICATED THAT MORE CEMENT WAS REQUIRED.

Oven. Temperature At Start Of Test *F Time-Sample In.0ven (Sealed) hrs.

Oven Temperature When Sseple. Removed *F

' Time. Outside Oven Before Unsealing hrs.

Solidification Results Free Liquid,.If Any _

ml (Approximate)

Relative Set-(Very Hard, Firm, Soft)

Unusual Appearance.(Color, Foam, Stratification)

I k

- 23 _

T e.

EXHIBIT 4' CNSI SOLIDIFICATION WORKSHEET II (Full-Scale sollairication.ur rarticulate Wastes)

NOTE: 'THIS INFORMATION 'IS CONSIDERED PROPRIETARY 'AND IS NOT TO BE

-RELEASED'OR COPIED WITHOUT WRITTEN PERMISSION OF CHEM-NUCLEAR SYSTEMS, INC.

Volume Information Date: Operator: Utility:

- ( a)' Usable Liner Volume (Table 2) Ft3 (b) Liner Ft 3/ Inch Of Height (Tables 2) Ft3 /In.

~ Waste A] arm-Height (To The Nearest 0.1 Inch)

'(c) Waste Volume =., (a) Ft3 (Liner vol. ) x 0.643* =

• A factor providing for 2 5 to 1.0 waste volume to binder ratio and a 10% volume allowance for additional cement, if required, lo assure a satisfactory mix. Express result to the nearest cubic foot.

(d) Waste Alarm Height = . (c) +. . (b) = Inches

(waste vol.) (v/n Hatio)

I Lime Weight' And (ir caustic Height is to .(Nearest Lb. & 0.1see note below) nch) be used, (e) Lime WT. = . .

gm x'O.623** x . (c) = Lbs.

SW 1, (f) Lime (Waste Vol.)

(f) Lite Height = = . (e) + 137*** + . . (b) = Inches (Lime WT.) (v/n natio)

• • • Approximate fluid lime density, Lbs./Ft3 Cement Weight And Alarm Height (Nearest Lb. & 0.1 Inch)

.( g) Cement WT. = gm. x 0.623** x , (c) . = Lbs.

sw 1, (g) (waste vol.)

• • A factor converting grams PCP additive weight per 100 ml waste sample to pounds required'per ft2 waste.

l (h) Cement Height = . ( g ) . + 173 * * * * + . _ (b) = Inches

, (Gement WT.) (V/h Hatio)

• • • • Typical true cement density, Lbs./Ft3 (1) Cement Alarm Height = (d)+(f)+(h) = Inches

. NOTE: IF 50% CAUSTIC IS USED INSTEAD OF LIME, DETERMINE GALLONS REQUIRED AS FOLLOWS, BUT DISREGARD THE HEIGHT OCCUPIED. THE FACTOR .0748 CONVER"S ML OF CAUSTIC PER 100 ML WASTE TO GAL-

, LONS CAUSTIC PER FT WASTE.

.. ml x .0748 x . (c) = Gallons sw 1, (r) caustic (waste vol.)

4 e-TYPICAL SAMPLE-CALCULATIONS'FOR WORKSHEET II-(Particulate Wastes)

NOTE: THIS INFORMATION IS CONSIDERED PROPRIETARY AND IS NOT TO BE RELEASED OR COPIED WITHOUT WRITTTEN PERMISSION OF CHEM-NUCLEAR SYSTEMS, INC.

A ~ slurry 'of radioactive - mixed bed resin beads is to be dewatered-and solidified in a L6-80 liner. After adjusting a laboratory.

sample so that ~ 100 ml of fluidized material ~ was measured for-

.. testing, it was found that (4) four -portions of. lime (2 grams each) raised. the pH to .about 11. Addition of three more grams of lime and 90 grams of cement formed a . smooth mix, which . set firm and. dry in the sealed container after 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> in an oven

. controlled at about 125*F.

(a) Usable Liner Volume (Table 2) = 79 Ft3 (b) . Liner Volume / Height-Ratio (Tables 2) = 1 53 Ft 3/ Inch '

(c) Waste Volume = 79 I 0.643 = 51 Ft3 (d)l Waste Alarm Height = 51 + 1 53 = 33 3 Inches 4

(e) -Lime Weight = 11 x 0.623 x 51 = 350 Lbs.

(f) ' Lime Height = 350 + 137 + 1 53 = 1.7 Inches (g) Cement Weight = 90 x 0.623 x 51 = 2860 RLbs . -

(h) Cement Height = 2860 + 173 + 1 53 = 10.8 Inches

-(i) Cement Alarm Height = 33 3 + 1.7 + 10.8 = 45 8 Inches

+

p

r. .

b

h-EXHIBIT 5

_CNSI SOLIDIFICATION WORKSHEET III-(Process Summary - Particulate Wastes

.N0TE: THISl INFORMATION IS CONSIDERED PROPRIETARY Utility:

AND IS NOT TO BE RELEASED.0R COPIED WITHOUT. Operator:-

. WRITTEN. PERMISSION-OF CNSI. Waste Tank 1.. Waste Slurry Addition No.1:

Start Time Date Finish ' Time Date _

-2.~ Dewatering-No.-1, If Necessary:

Start Time Date Finish' Time Date

3. Waste Slurry JAddition No. 2, If Necessary:

Start Tige Date Finish Ti'ce Date .

4 Dewatering No. 2, If Necessary:

, Start Time Date Finish Time Date 5.- . Water Added-To Re-Fluidice, If.Necessary:

Estimated Volume Time Date Added Gal.

6. Waste Temperature After Mixing: 'F l '7 Lime Added:

Start Time Date Finish Time Date Wei 6ht Lbs.

8. Temperature After Mixing In Lime: *F

" ~

9 Cement Added:-

Start. Time Date Finish Time Date Weight Lbs.

i . 10. Additional Cement Added, If Necessary: Lbs.

11. Temperature After All Cement Added: *F

12. Agitation Etopped: Time Date

e 13 Initial Temperature After Agitation Stopped '*F 6 Hours. Later (From ' Chart Recorder) *F 12.- Hours -Later (From Chart Recorder)

• F 24 Hours -L'ater (From Chart Recorder) 'F 14 Peak Temperature Time Date_

15.- Fillhead Removed: Time Date~

16. Liner Capped: Time Date

17 Observations, Additional Comments:

1

+

.oo. .I a c~

TABLE 2-

' Liner and Cask Calculations Liner- 121-300 I21-235 L14-195 L14-1'?O 18-120. L7-100' I6-80 Diameter 82" 82" 76" 74" 61" 74 5" 58"

. Height- 104 5" 79" 75 5" 69 37" 71 5 " 37" 54" Total Volume, 317' 241 196 174 120 93 82 (FTQ le Volume,

-(FUsgt ,' 2" Safety ~ . .

Factor) 311 235 190 169. 116 88 79

'Ft/In.

3 2.62 2 52 1.69 -2 52 1 53 Of Height 3 05 3 05 Weigit (Lbs.).. '2400- 1800 1650 1550 1100 1250 1100 Cask Pa 27250 27250 17700 14000 200D0 '13000 7500

-(Lbs.)yload, t

e I

L l

l

U.S. Nuclear Regulatory Comunission , April 18, 1983 If you have any questions concerning this mtter, please get in touch with R. H. Shell at FTS 858-2688.

Very truly yours, TENNEESSEE VALLEY AUTHORTIr a

L. M. Mills, llanager Nuclear Licensing Sworn to and subscrihJ d bef9rp me

.this / f#6y of / h _fl983 e/f/_-se ~

W/X2 ' .---

'Not '

My Public sumission Expires #!f! 4 s / '-

Enclosures (3) cc: U.S. Nuclear Regulatory Conunission Region II Attn: Mr. Jatnes P. O'Reilly Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

ENCLOSURE 1 Letters From'TVA To NRC-OIE Region II a

• * * * *

• s 5 w rAhs A .p. _g -

,,,4,,,,, _,

7-A27 82.0928 022 ~

400 Chestnut Street

• Tower II ..

i

!. .. September 28, 1982 .^.'.* ..r. .

m. r " -

a ..

BLRD-50-438/82-27 J- .,

' -.~

. - 3 J 'BLnD-50-439/82-24 ,

. ~ ' '

- U.S. Nuclear Regulatory camimMon ~

~

. Region II .

Attn: Mr. James P. O'Reilly, Regional Administrator ~

.m 101 Marietta Street, Suite 3100 ... .... :r ...L..N..,..,~..............-. ~ .~ ~

.; Atlanta, Georgia 30303

Dear Mr. O'Reilly:

- - ^

BELLEF0tlTE NUCLEAR PLANT UNITS 1 AND 2 - INSOLUBLE GLUE USED POR PURGE DAMS w.. -1 IN STAtiLESS SIEEL PIPING - BL3D-50-438/82-27, BLED-50-439/82 FINAL ,-

. REPORT . .

M The subject deficiency was initially mported to NRC-0IE Inspector ~- ~

., 'B. Y. Crlenjak on March 22, 1982 in accordanoe with 10 CFR 50.55(e) as S

NCR 1725. This was followed by our. interim mports dated April 22 ,

T . ; ' --

'and June 18, 1982. As discussed with Mr. Crlenjak by telephone on. .. 2, .. ..

T September- 10, 1982, our final maponse was delayed. Enclosed is our - :{ . '~ . .,

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. 3. . . :- .

. If you have any questions concerning this matter, please get in touch with

. D k.. , . . . c. R. H. Shell at PTS 858-2688. ._ . . , c. 77 ..

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7 : '" Office of Inspection and Enforcement i

U.S. Nuclear Regulatory Comission C ,' Washington, D.C. 20555 '

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_ _ - . . . - - .~ . ..

ENCLOSURE i

BELLEFGITE NUCLEAR PLANT UNITS 1 AND 2 INSOLUBLE GLUE' USED FOR PURGE DAMS IN STAINLESS STEEL PIPING NCR 1725

,s BLRD-50-438/82-27, BLRD-50-439/82-24 10 CFR 50.55(e)

FINAL REPORT Description of Deficiency 1

-2 Some glue used in installation of purge dams in stainlass .stesi piping appeared insoluble during flushing activities, and minor glue residual-remains in piping at purge dam locations. This problem was anticipated during the resolution of nonconformance. report (NCR) 835. The disposition -

of NCR 835 directed discontinuing the use of Elmers Glue-All and --

recommended using Elmers School Glue. The insoluble glue residual has been identified as Elmers Glue-All used before NCR 835 and Elmers School Glue that.has been affected by heat from welding activities. When purge dams-are located too close tc the welds, the currently used and normally soluble Elmers School Glue will char and become much less soluble.

. Safety Implications It has been determined through tests and analyses described below that no

. condition adverse to the safe operation of ths plant exists. This conclusion is based en the following observations:

1) The; purge dams will not'cause stress corrosion cracking of the pipe.

2) Very little purge dam residual remains en the pipe wall after preoperational flushing. The residual remaining will all dissolve i -

during plant operation. Solubilized purge dam material is not harmful to the systems. Any particles that may break loose before dissolution -

, is complete will not obstruct any piping or instrument lines.

Corrective Action

~

Based on the, attached, supporting information, TVA ha's conclud.ed that glue residual 'left 'in11 ping systens 'willYnot 'cause' a" safety' problemNWONO-MM Laboratory tests have shown that even the glue that was initially thought t

to,be insoluble $illTdissolvei,; Flushing of, systems;thus;farshas;shown;thaty 9 demineralized water flushing can achieve ~ removal'of enough'of the purge dam. g

7'%, -

l residue so that the possibility of large pieces breaking loose is highly ,

( unlikely. TVA will revise the acceptance criteria for' proof flushing

( particulates to allow purge dam particles up to 1/8-inch in any dimension.

l This revision will be accomplished by November 8,1982.

I In addition, purge dam residual on the pipe wall will be acceptable provided that the system has met the proof-flush acceptance criteria. The rf.act.or coolant pump seal water injection _,line in the Makeup and Purifica-l tion System will be flushed with acetic acid to remove as much of the purge

[ dam residue as possible. This will be accomplished by October 15, 1983

! TVA has revised the welding specifications to ensure that purge dams are placed far enough from the weld to prevent charring of the glue. TVA has also increased welder awareness that substitution of the specified Elmers

School Glue is not permitted. No other TVA nuclear plants are affected by l this problem.

JL l

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2 Sham a a 1 - . ..

- .- _ .- - . . - . =

I ATTACIMtirr ' ~

. SUPPORTING INFORMATI0tf FOR HCR 1725 Metallurgical Testing Metallurgical testing and' chemical analysis has shown that; residual ,

purge das materials remaining in contact with 304 stainless steel will i have no detrimental effects on the piping material during operation of

• the plant.

. - 1 The Dissolvo. Water soluble purge paper (IED-60) contributes virtually all of the halides present in the purge, dam residue. Specific ion- ,

tests have shown leachable chlorides in.the range of 170-200 parts per ^*-

million. . -

l Tests show that purge das materials closer than 3/4-inch from the edge

( of a weld reach a temperature of approximately 600 F. At this

- temperature the material carbonizes to the extent that it flakes off much the same as food in a self-cleaning oven, and subsequent flushes >

remove the flaking material.

Two. potential modes of cracking have been addressed:

1. Stress Corrosion Cracking (SCC)

The purge dam residue is a minimum of 3/4-inch from the edge cf the weld. This is beyond the distance at which residual stresses from welding are present. In the absence of tensile stress, SCC does not occur. '

2.

~

Intergranular' Stress Corrosion Cracking (IGSCC) --

~ ~'

. i The heat affected zone (HAZ) of 'th'e weld extends to a 'maxhm of approximately 3/1fi-inch from the edge of the welds. As stated previously, the purge dans are located a minha. of 3/4-inch from -

l the weld and, therefore, the potentially. aggressive environment is .,

- - - - o not presentMrUtheLHAZ.w s W s+a8f 4 N M W *+ 4 M 4 N M

• M. . ..,,.. . ..W^"'*'"> 4*J Additional tests performed at-TVA Singleton Laboratory determined thatW+t em-".'" 4.'

~

'no ' harmful"effectsPsh'cI61dWe556ted'everi"itWiE g mn 7A er "i d~31[DD 575E.

were left in contact with the base material. . Samples of glue with i added chloride legels of ove5 1000 ppa were baked on pipe samples and autoclaved at 150 F and 550 F in borated water. After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> r

virtually all chlorides were leached from the glue at both temperatures. The 304 stainless base materials were subsequently examined microscopically for corrosive effects.

After 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of exposure there was no apparent attack. Because

~

virtually' all chlorides leach out of the glue after .24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of exposure, TVA anticipates no adverse effects from the relatively small amount of material remaining. ,

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~ Attachment- l Page 2

-TVA can anticipate no harmful effects on the stainless steel pipe as a result of purge ~ dam Maiduals remaining in contact with the stainless steel pipe during system operation.

Acetic' Acid Testing and Flushing . ' #

Laboratory testing was performed to determine what solvents are

' available that' could be used to remove.the glue from .the pipe.

Testing showed that acetic acid was the most promising solvent. . ,

Acetic acid aided in the removal.of the noncharred glue; however, it .

~

did'not have an appreciable effect on the charred glue. The second interim mport on NCR 1725 stated that acetic acid would be tried out on a system that had not been previously flushed.~ Since there were no systems available that had not been flushed, the trial was run on the Reactor Building Spray System (with the ' exception of the spray headers -

and the sodium hydroxide tank and piping).

The Reactor Building Spray System had been previously flushed with.

water, but removal of a flanged spool piece revealed noncharred purge cam residual en the pipe wall. Thus the pipe interior could be visually inspected before and after the acetic acid flush. The system was flushed with 5 pergent acetic acid for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at

temperatures up to 145 F.. Inspection of the piping after the acetic acid flush showed that, most of the purge dam residuals had been

' removed from the pipe wall. _

Autoclave Tests -

i Autoclave testing was performed _to determine what effect high -

, temperature water will have on charred glue since it is the most insoluble. Stainless steel coupons were prepared using both Elmers

(

Glug 400 F and 500AllandEgmersSchoolGlue. F to simulate purge damsCoupons that were were placed baked tooinclose an oven to , at the welds. Half of the coupons representing all of the above -

i

.v. , s .

.n conditions were:soakedlin; acetic.aoid,to.simulatetac, etic geid flushinggg,g,,,j yg '

,,,.g g of the piping systems.

%, m,y .4 .%.<., . . . n . .. .. . o. . 3 . % .. a .~ m ,., y , . . .a.

. - m ....The coupons wer%.w e u % ,,,e : placed ciri . the

• autoclave :which r contained '

borated- wat representative "of reactor' coogant. - Ths, autoclave was operated at .n temperatures-ranging-from 200 F to 500 F to identify temperature  !

effects en the glue. The test results show' that the charred glue will dissolve, and that the autoclave temperature is the only variable ghat has an effect on the dissolutica rate of the charred glue. At 200, F, about 6 percent of the charred glue dissolved in 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />. At 300 F,

~

19 perce".t of the charred glue dissolved in 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />; at 400 percent of the charred glue dissolved in 51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br />; and at 500,F, F, over 84 93 percent of the charred glue dissolved in 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

These results show that given enough time, the glue deposits will eventually dissolve. The results also show that any glue particles that get into - tge reactor will dissolve in the reactor, since it operates at 600 F.

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Page 3 '

i .

- Demineralized Water Flushing Several systems' have been flushed with domineralized water to date.

These include the Spent ~ Fuel Cooling and tha Reactor Building Spray Systems. Three flow ~ paths on the Spent Fuel Cooling System were flushed with unheated domineralizer water. One flow path could not meet the acceptanco criteria of 1/32-inch by 1/16-inch particle size.

However, the particleg were less than 1/8-inch. The flow path was then fltahed with 180 F water. After the hot water flush, the acceptance criteria could still not-be met, even though the particles ,

being detected were still less than 1/8-inch. Spool pieces were ,

l removed so that the pipe interior could be visually avamined. . Reactor , . ,

building spray train L was also flushed with cold domineralized water before the acetic acid flush. The path was flushed to the 1/32-inch ~

1/16 inch particulate acceptance criteria with demineralized water.

Inspection of tte pipe interior after the flush showed some noncharred

,- purge dam glue _ ridges in the pipe. Flushing of these and other flow paths has demonstrated that the systems can be flushed to a point -

where only tightly adherent glue ridges are left in the pipe and that only small particles break loose from these ridges during system i

operation.

- Safety Analysis of Particulates All of the systems were analyzed with respect to problems which could be caused by particulates breaking loose from purge dam residuals during plant operation. The analysis was based en the assumption that -

glue particles up to 1/8-inch could be present in the operating 1

systems. Based en this analysis, plant safety will not be compromised _ =.

with glue particles up to 1/8-inch present in the Waste Disposal (WD), -

l Chemical Addition and Boron Recovery (CA&BR), Reactce Building Spray -

(RBS), Core Flooding (CF), Decay Heat Removal' (DHR), Spent Fuel Pool Cooling and Cleanup (SFPCC), and Makeup and Purification (MU&P)

Systems. Pumps in the RBS, DHR, SFPCC and MU&P Systems are equipped -

with cyclone separatorsr in the . seal water. supply so that pprticles ,ing.ggg.pg gl - ,

e- the seal water'would"be removed, before ~ getting to'the pum,p seals.

The ' '

water in instrument sense lines is stagnant; therefore, it is highly unlikely that purge _ dam p , ,,. ,,

. lines or cause: problems.. tic y> esicould finditheigwaypto.instrumentg,;,p;g,,&y

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