ML20082P296
| ML20082P296 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/18/1983 |
| From: | Muller D Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20079F427 | List:
|
| References | |
| FOIA-84-35, TASK-3.D.1.1, TASK-TM NUDOCS 8312080188 | |
| Download: ML20082P296 (51) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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Docket Nos. 50-400/401 MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing, DL FROM:
Daniel R. Muller, Assistant Director Radiation Protection, DSI
SUBJECT:
METB INPUT FOR SAFETY EVALUATION 1tEPORT FOR SHEARON HARRIS, UNIT NOS. 1 AND 2 PLANT NAME: Shearon Harris
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CICENSING STAGEi OL DOCKET NUMBER (S): 50-400/401 RESPONSIBLE BRANCH: LBf3; B. Buckley, LPM REVIEW STATUS: Continuing Enclosed for your use is the Effluent Treatment Systems Section, METB, ir.put to the Safety Evaluation Report (SER) for Shearon Harris Nuclear Power Plant.
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' nce the SER is on CRESS, we have marked-up the lates't draft of the SER to Si reflect changes in the status of open items.
Based u'pon our review, the confirmatory items are:
1.
Description of polymer binder system (11.4).
2.
Drawing (s) on seal water, BRS, ~etc.~ filter Oudge handling (11.4).
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3.
Location of Turbine building vent monitor (10.4.2,10.4.3 and 11.5).
The open items are:
1.
Applicant possesses no method for detemining releases of noble gases from the mechanical vacuum pumps during hogging operations (10.4.2 and 11.5).
2.
Applicant has no means for continuously sampling for radioiodines and i
particulates from the mechanical vacuum pumps during hogging operations l
(10.4.2 and 11.5).
3.
Applicant has no radioactivity monitor on the discharge from the service water system, waste procassing building cooling water, and the reactor auxiliary building backwash return (11.3).
4.
Applicant has not included all the appropriate systems and/or components in the leak reduction program (TMI Item 111.D.1.1 and 9.3.5).
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XA Copy Has Been Sent to PDR l
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NOV 18133 N-T. M. Novak If there are any questions concerning this input, please contact J. Hayes (x27649) who is the reviewer for the Shearon Harris plant.
Original signed by Daniel R. Mult Daniel R. Muller, Assitant Director for Radiation Protection Division of Systems Integration
Enclosure:
As stated
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cc:
R. Mattson
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R. Capra B. Buckley C. Willis i..
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DISTRIBUTION:
Docket File 50-400 Docket File 50-401 (w/o enc 1)
METB Reading File METB Docket File ADRP Reading File l
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- The scope of review of the main condenser included layout drawings and descrip-tive information.in FSAR Section 10.4.1.
The basis f acceptance in the staff review was conformance of the design criteria bases nd design of the condenser to the acceptance criteria in Eti h of SRP
- 0. 4.1, d industry standards.
Based on its review, the staff concludes that the main condenser is in confor-mance with the above-cited criteria and design bases, can perform its designer function, and is, therefore, acceptable.
10.4.2 Main Condenser Evacuation System 10.4.2.1 Summary Description 5
The main condenser evacuation system (MCES) of each unit consists.of two 100%
g capacity mechanical vacuum pumps that serve the main condenser. At startup, one or both pumps may be operated ta evacuate the condenser.
Once operating
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~ pre 7sure i's obtained, one pump is placed on standby.
At startup and before
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turbine operation, the noncondensible gases will be discharged irectly to the atmosphere in the turbine building areawithout filtration. With turbine operation, the discharge frt:3 the mechanical vaccuum pumps is directed to the
' turbine building vent stack without filtration.
Thenoncondensiblegasesfiowtoamoistureseparatorwheremostofthewater
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vapor is condensed. The condensed water drains to the industrial waste sumps.
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However, the discharge from these sumps will be directed to the secondary pr> wAT
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aste system for treatment upon detection of radioactivity by monitor REM-332ft.
{ '{,* ".1 e airborne discharge from the mechanical vacuum' pumps is monitored for mult. W5
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radioactivity. Any radioactivity exceeding the monitor set point will initiate
- an alarm,by L..di e r - fi n. The applicant has indicated that there is no potentially explosive gas mixture present in the MCES during normal operation or during shutdown or startup conditions.
A ::: ore detailed discussion of the MCES is presented in FSAR Section 10.4.2.
10.4.2.2 Evaluation Findings The staff's review included the system's capability to process radioactive gases and the design provisions incorporated to monitor and control releases of radioactive materials in gaseous effluents in accordance with GDC 60 and 64.
The quality group classification of equipment and components used to collect gaseous radioactive eftluents was reviewed relative to the guidelines of RG 1.26.
The staff reviewed the applicant's system descriptions, piping and instrumentation diagrams, and design criteria for components of the MCES with respect to the acceptance criteria of SRP 10.4.2 (NUREG-02n0).
Aw(4seXL Od The staff,3 p ti g to the applicant
<ta+=d that the MCES containt h 4
provisionsforsamplingandmonitoringdischargesduringstartup(hogging) opera-tions as specified in Table 1 of SRP 11.5. /
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. The applicant has. rg'sporl_ed. by clarifying the de.s.cription of %. the hogging
d operation,+sses.hQuring hogging cperations the vacuum pumps will discharge to the atmosphere Q nt line 7AE12-19-1 through valve 7AE-B9-1.
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g W 1Gb a7 s unmonitored. /,during hogging operations, a portion of the s
vacuum pump e haust will be routed through the normal vacuum pump ex release path De through valve 7AE-833 past noble gas moni or m'-250'.
t y monitor RL" _I L L, :T f ;?i n actiorQ, be taken to close line 7AE12-9 w f
valves 7AE-B~ y,p Uf-39-1 on a high radiation signal and -th:. emt'..,
fL A&g PETS).
theoffgasAfougfiYhecondenservacuumpumpeffluenttreatmentsystem The CVPETS ccisists of a detaister, an electrical h para 11a.1.
g y g4, 4 It is the st. ff's position) hat the release of the offgas during hogging opera t
1 T ".;R 11.5.
As long as flow'is
. unit;..J....eted ' T..l. /,' the applicant would have a mea-tions must b radiationmonitorR$TV-353 heconcentratpnofnoblegasesreleaseQiuringhoggingopera-directed pas 2.. J..,g..ai 3-f _ _., s m
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It fi n c t. p; i th...di;ti r c ritr-r f thi unmonii..ed.;;. m.r......s.T}Becausetherad monitor doc not have the capability of continuous sampling of radici dr?" -et W --? % h.e,.,,1;...
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there is no means available for determining their release during g g particulateshogging opei stions and the requirements of Table 1 of SRP It is the s iff's position that no release may occur from line 7AE12-1-c.
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a Harris proc dures contain provisions for sampling and monitoring d sc during hogg ng operation, as specified in Table 1 of SRP 11.5.
%G.wb The applica t has indicated that the main condenser is constructed Exchanger I stitute's " Standards for Steam Surfa
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N as requirec by SRP 10.4.2.
The applier it M hrHeated that the quality group classification to wh MCES is der gned is nonnuclear sareT.y, Cai.sgory 1 for the condensate va purp efflui it treatment system and nonnuclear safety, Category The applicant has indicated, in FSAR Section 3.2, that 26.
these qual :y group classifications correlate with Quality Group D of R anical vac ;m pumps.
At the pre ent time the design of the MCES does not conform with S the MCES h s not met the requirements of GDC 60 and 64 with respect trol and e nitoring of releases of radioactive materials to the environme
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i 10.4.3 TL bine Gland Sealing System 10.4.3.1
.ummary Description i
The turbit i gland sealing system provides sea h
A portion of potential ascape of radioactive steam into the turbine building. d team supply is passed through the turbine gland seals the main hotWell w ile noncondensible gases are discharged by two 100% capa in the g1 ad steam condenser.
A more detailed discussion of the turbine gland seal:ng to the er ironment.
system is presented in FSAR Section 10.4.3.
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_.[\\_,.10.4.3.2 Evaluation and Findings N.,::y The staff has reviewed,the. turbine gland sealing system with respect to SRP 10.4.3 (NUREG-0800). The scope of this review included the source of sealing steam and the provisions incorporated to monitor and control relesses The staff of gaseous radioactive affluents in accordance with GDC 60 and 64.
has reviewed the applicant's system description and design criteria for the components of the turbine gland sealing system.
The applicant has indicated that the quality group classification to which the turbine gland se61ng system has been designed is nonnaclear safety, nonseismic Category I.
When compared to Quality Group D of RG 1.26; this conforms to SRP 10.4.3.
he ventir the turbine gland seal condenser'c noncondensible gases se A"5
'y monitored'for noble gas"as required by Table 1 of SRP 11.5 but not samp,leds.L f.
continuously for radiciodines and particulates as required by4RT 11.L De-n eff.411 r: g r: a..pi !. 3.. J., ; t.! a ;,1.... m i -..ianc sha:t :r
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'JH S*cth-;D 4M--. - nt oy cae opplisat i: ret tt: B iG.
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conclude 5that the turbine gland sealing system meets the requirements of GDC 60 and 64 with respect to the control and mor.itoring of releases of radioactive materials to the environment by providing a controlled and monitored turbine gland sealing system.
10.4.A Turbine Bypass System 4:/
The turbine bypass system is an integral par of the steam dump system. 4he X
turbine bypass consists of six pneumaticall operated valves connected to the main steamline downstream of the MISVs ischargi5g directly to the main condenser. The turbine bypass is capa le of dumping 35% of rated steam generator flow to the condenser. The steam dump system (atmospheric and condenser) is capable of withstanding a 100% load rejection without tripping the reactor.
During normal reactor operation, the turbine bypass system (condenser steam dump) functions to control the temperature in the reactor primary loop.
During hot standby and synchronization, the system is used to msintain secondary system pressure.
It is also used for decay heat removal during shutdown. The a
U turbine bypass valves are designed to fail closed on loss of control signal
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and/or' control air pressure. Ths sy)em control signals will be blocked in the g
event of high main condenser pressure.
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The applicant will include pr{ operational and startup tests of the turbine bypass system in accordance with recommendations of RG 1.68, " Initial Test Programs for Water Cooled Reactor Power Plants."
he adequacy of the test X
program is evaluated in Section 14.1 of this repor[t.
4 The turbine bypass J
system can be tested while the unit is on line; ad will be tested en a semi-I annuni basis.
14 The turbine bypass system meets the recommendations of BTPs ASB 3-1, "Protec-tion Against Piping Failures in Fluid System Piping Outside Containment," and l4
.O MEB 3-1, " Postulated Break and Leakage Locations in Fluid System Piping Outside 6
4 10-11 j
Shearon Harris SER b
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Insert A to 10.4.2 continuously sampled for radiotodines and particulates and continuously monitored for noble gases as noted in Table 1 of SRP 11.5.
Insert B to Sectiorf 10.4.2 However, in order to determine the release of noble gases through the hogging valve, the applicant must have some means of correlating the radia-r
-tion monitor. readings and the flow past the monitor with the flow and discharge concentration through the hogging valve. The applicant has not presented such means.
/
Insert C to Section 10.4.2 In addition, the failure of the monitor to have this sampling capability could lead to interference of the particulates and radiciodinas with the noble gas readings.
L Insert D to Section 10.4.3 The applicant has committed to routing the exhaust from the gland seal con-denser exhaust to the turbine building vent stack. There continuous sampling for radioiodines and particulates will be provided. With this commitment...
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s Document Name:
S EARRIS DRAFT SER SEC 11
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Requestor's ID:
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STEPH Author's Name:
Thomas /Kadenbi Document Comments:
PIIASE RETURN THIS SHEET WHEN SUBMITTING REVISIONS
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- g.. ;. x 11 RADI0 ACTIVE WASTE MANAGEMENT 11.1-Source Terms 11.1.1 Summary Description The applicant calculated the liquid and gaseous effluents from Harris utilizing
. the PWR GALE computer program. The applicant utilized the source assumptions
-of RG 1.112, " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Eff_luents. from Light-Water-Cooled Power Reactors", and NUREG-0017,
" Calculation of Releases of Radioactive Materials in Gaseous and Liquid Efflu-ents from Pressurized Water Reactors (PWRs)." Gaseous erfluents were calculated from such sources as offgases from the main condenser evacuation system; leakage to containment, the reactor auxiliary building, and tne turbine building; noble gases stripped from the primary coolant during normal operation and at shutdown; g(.
and cover and vent gases from tanks and equipment containing radioactive material.
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Liquid effluents were calculated from such sources a;
% bleed, leakage col-1ected in equipment, and floor drains such as those f-in the reactor auxil-Tary building, and fuel handling, waste processing, and turbine buildings; and contaminated liquids from anticipated plant operations such as resin sluices,.
filter backwash, decontamination solutions, sample station drains, and detergent wastes.
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The staff has performed an independent calculation of the primary and secondary coolant concentratione and of the release rates of raifoactive materials using the information supplied in the FSAR, the GALE computer program, and the meth-odology presented in NUREG-0017. Table 11.1 presents the principal parameters that were used in this independent calculation of the source terms. These source terms were utilized in Sections 11.2 and 11.3 to calculate individual doses in accordance with the mathematical models and guidance contained in RG 1.109, " Calculation of Annual Average Doses to Man From Routine Releases of Egactor Effluents for the purpose of Evaluating Compliance with 10 CFR Part 50, k.-1 Appendix I."
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10/26/83 11-1 S HARRIS DRAFT SER SEC 11
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d laundry and
%,- Liquid effluents occur from the waste monitoring tanks, the treate
' -- O The sources the hot shower storage tanks, and the secondary waste sample tanks.
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One source of wastes to these tanks are discussed in Section 11.2 of this SER.
of waste to the waste monitor tanks that is not discussed in Section Distillate from the BRS evaporators can be pumped boron recycle system (BRS).
to the waste monitor tank for discharge offsite.
The staff's estimate of the liquid affluents was based upon the information pre-sented in Tebles 11.1 and 11.2.
The applicant assumed that floor drain wastes would be treated by the reverse osmosis (RO) unit of the floor drain treatment The staff calculated liquid effluents assuming that the floor drains f
subsystem.
However, the results indicated that more than would be treated by the RO unit.
" 5 curies per' year per unit would be released based on the staff-projected inputs to,the floor drain treatment subsystem. Because this would not comply with o of the requirements of the Annex to Appendix I of 10 CFR 50, which the applicant chose to use to show compliance with Section II.D of Appendix I, the staff assumed that wastes collected by the floor drain tanks would be treated by the The applicant had wasta evaporator in the equipment drain treatment subsystem.
indicated in the FSAR that these evaporators would be available to treat the l
The staff then calculated
- floor drain wastes when they contained high activity.
With this the effluents from floor drains based on the use of this evaporator.
evaporator in use, the effluents from Harris could satisfy the criterion of Se tionA.2oftheAnnextoAppendixI.y F
Av!.r, err.3 the staff determ g that adequgte holdup and processing t g In M: rc:'"-+8~,
were available for the treatment ofye floor drain wastes and the equipment drain wastes lej W tt < \\/Afo 'sto r*
The applicant assumed in his analysis that the wastes collected by the seco s
waste low-conductivity holding.~ tank would be processed by an evaporator The staff's review of the applicant's des-tion to a mixed bed domineralizer.
cription of this system indicated that these sastes would usually be treated Therefore, the staff assumed the latter mode of treat-only by a domineralizer.
ment in its analysis.
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S HARRIS' DRAFT SER SEC 11 11-2 2:[
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The holdup time calculated by the staff for the treatment of the reg ih solutions from the cond,atnsate polishing system (input to secondary
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Because the
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conductivity holding tank) was calculated to be less than 2 days.ilable secondary waste evaporator, which was intended for Units 3 and 4, is a for processing the contents of the high-conductivity holding tank if th had rator for Units 1 and 2 becomes inoperable, no alternative treatment s days holdup to be considered in. lieu of the evaporator, even though less than 2 is available for the treatment of the regenerates.kThe staff assum chemical drain wastes from the chemical drain tank of centrate from the laundry and hot shower RO unit would be sent to t The applicant did not include this source in his trates tank before discharge.
evaluation of affluent releases.
I-All detergent wastats were considered by the staff to be collecte the laundry and hot shower RO unit, and then discharged.
tin-Airborne effluents occur from the building ventilation systems, from t (GWPS),
uous and pre-entry containment purges, from the gaseous processin d
r the main condenser evacuation system, and the tu-bine gland steam c
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All airborne effluents except those released from the turbine gland s EPA denser, the main condenser vacuum pump, and the GWPS are The continuous con-filter and charcoal adsorber before they are discharged.
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in the-tainment purge is filtered entyn by a HEPA filter and charcoal a sor er airborne radioactivity removal system (ARRS) ins'ide the containment.
Apd Dy L ib releases t{ogi informgi,ong lized by the staff in its estimate o IAd y
isgin Tables 11.1 gwaste systems are in Sections 11.2 and 11.3 of this SER.
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The applicant is installing a fluidized bed dryer to process evapo lid radwaste trates(bottoms)gndfiltersludgestoreducethevolum
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shipped offsite.
Airborne affluents will result in additional liquid and airborne effluents.
tinuous basis result from the VR system's offgas and w'ill be discharg
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while' the system is operating.
However, based upon charged directly off site from the VR equipment operation.
3 S HARRIS DRAFT SER SEC 11 s; a 11-3 i
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Table 11.1 Principal parameters and conditkns used in calculating -
releases of radioactive material in liquid and gaseous
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effluents from the Shearon Harris Nuclear Power Plant GENERAL 2900 Reactor power level (MWt) 0.80 Plant capacity factor 0.12%*
Failed fuel Primary system 3.42 x los Mass of coolant (1b) 60 Letdown rate (gal / min) 1.44 x 108 Shim bleed rate.(gal / day) 100 Leakage to secondary system (1b/ day)
Leakage to containment building (1b/ day) 160 Leakage to auxiliary building (1b/ day) 2 Frequency of degassing for cold shutdowns (times / year) 6.0 Letdowh cation domineralizer flow (gal / min)
Secondary system 1.2 x 107 Steam flow rate (1b/hr) 1.01 x 105 Mass of liquid / steam generator (1b) 9.00 x 108 Mass of steas/ steam generator (Ib) 1.53 x 108 Secondary coolant mass (1b) 1.7 x 108
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Rate of steam leakage to turbine area (1b/hr)
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3 2.3 x los Containment building volume (ft )
4
Frequency of containment purges _(times /yr) 3 1720 Containment low volume purge rate (ft / min) 3 104 Containment atmosphere cleanup rate (ft / min) 16 Pre purge cleanup time duration (hr)
Iodine partition factors (gas / liquid) 0.0075
. Leakage to auxiliary building 1.0 Leakage to turbine area 0.15 Main condenser / air ejector'(volatile species)
"This value is constant and corresponds to 0.12% of the operating power pro-duct source term as given in NUREG-0017.
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- 1%/ day of the primary coolant noble gas inventory and 0.001%/ day of the pri-mary coolant iodine inventory.
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LIQUID RADWASTE SYSTEM DECONTAMINATION FACTORS s.-
Laundry and
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Equipment Secondary Secondary r
Boron drain waste high waste ' low hot shower RO concentrate recycle treatment conductivity conductivity subsystem subsystem subsystem Material system system 8
104-102 108 104 Iodine 105 10
- Casium, 2x168 104 105 2
105 102 104 iskubidium Other 104 10,4 I
LIQUID WASTE INPUTS Decay
. low rate Fraction Fraction Collection time
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- I-F discharged time (days) (days)
(gpd) of PCA 0.1 23.3 3.11 Stream Shimbleed rate (BRS) 1,440 1.0 24.4 0.46 250 1.0 0.1 0.17
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838 0.002 1.0 2.23 Equipment drains (EDTS) o o
o,o RO concentrates wasteson 1;,;;;
1.0 21.4 0.46 Illi 935 0.11 0.50 0.21 Blowdown Floor drains (FDTS) 6000 1.0 Regenerant solution 1.0..
8.7x10g 1.0 0.47 0.13 (SWTS) 450 Detergent wastes 19,000
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Low conductivity holding tank Volume / year / unit Source of Volume Reduction System Wastes 3
1025 ft Evaporator bottoms
'960 ft3 Recycle evaporator 4675 ft3 Waste evaporator
'876 ft3 Secondary waste evaporator RO concentrate s
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GASEOUS WASTE INPUTS There is continuous low volume purge of volume control tank.
70 70 Holdup time for)hnon (days)
Holdup time for krypton (days) 35 Fill time of decay tanks (days)
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Decontamination factors for individual equipment items --
Table 11.2 e.
All nuclides
'except iodine Iodine
- 1. EVAPORATOR p 'r 104 10s
@ Secondary waste und wasta 103-10 Other
@ f fecycle
- Cesium, nuclides Anions A/ubidium L DEMINERALIIERS-102 102 2
10 W Secondary waste (mixed bed) 1 10 -
laundry;RO package and
@ CVCSj 10 waste monitor tank, cation bed 10 2
W Recycle evapcrator feed, mixed bed 1
102 1
(M Recycle evaporator condensate,
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anion bed Others Iodine
- 3. VOLUME REDUCTION' EQUIPMENT 100 2
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. (fd Fluidized bed dryer and gas / solids seperator 100
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@ Scrubber /preconcentrator 100 1
'd HEPA filter 1
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'OC reoal adsorber All nuclides 4 RO UNITS 30 Laundry and hot shower. _
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from the scrubbers b Id t fW
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~ 'FSAR Fig 6te 11.4.2-2, decontamination solutions, condensate ditional and leakage from pumps, pipes, and so forth will result in ad Ultimately, some of wastes being treated by the floor drain treatment system.
itor tanks and of these wastes will be discharged off site from the waste mon
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some will again be treated in the VR system.
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VR system The staff has estimated the quantity of wastes to be treated by and the radioactivity associated with these wastes.b rne effluents from the i
the additional' amount of radioactivity released as a r o t
These VR system and as liquid effluents from the liquid radwaste sys e T
' 'j 5 HARRIS DRAFT SER SEC 1 11-6 10/26/83
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using NUROG-0017, and the i, i
' releases were includ with the rel ses calculate
^nv ronmental total quantity of of uantsis(i'n on 5 of the Shearon Harris
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Statement (NUREG-097.3-). -T.:,1;. 11.1...
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The liquid waste processing system (LWPS) consis s of proc l
d/or inst.rumentation necessary to collect, process, a nitor, and recy discharge of' radioactive liquid wastes.
ii f the The LWPS is designed to collect and process was as based i ity.
All liquid waste warta in the plant and the expected levels of r dioact v l
s Before is processed on a batch basis to pemit optimurr control of re e types and liquid waste is released, samples are analyzed.o determine
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amounts of radioactivity present.
l d for eventual reuse in Based on the waste' treatment system utilized, the waste may se recyc ed to the envir L
tra plant, retained for further processing, or releaseA controlled conditions.
i h ges if ious discharge tanks will automatically termir te liquid waste evel.
radiation measurements exceed a predetermined 1 and 2, in the waste pro neously actuated in the control room for Unit:
building control room, and in the health phys :s control room.
l compor nts considered in the calculation T.
.a.
.The design parameters of the prinicpa Table 11.3.
The LWPS is of liquid effluents from the Harris plant are shown in
- W' composed of the following subsystems:
' 3 equipment drain treatment (1) floor drain treatment (2) laundiy and hot shower treatment (3) secondary waste treatment (4) f f
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Table 11.3 design parameters of principal components considered in the
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c ticulation of liquid effluents from Harris Units 1 and 2 Capacity Safety Component' Number (each) class Boron Recycle System Meycle evaporator feed domineralizer 2
30 ft3 3
t#ecycle evaporator feed filter 2
150 gpa 3
v(ecycle holdup tank 2
84,000 gal 3
,. vftecycle evaporator feed pump 2
30 gpa 3
Recycle package 0
2 15 gpa 3 & NNS Utecycle evaporator egncentrate filter 2
35 gpa NNS Utecycle evaporator condensate domine:ralizer 2
20 ft8 NHS th eycle evaporator condensate filter 2
35 gpa NNS
~
Recycle monitor tank 2
10,800 gal NNS
~
Recycle monitor tank pump
/
2 30 8,p NHS
~
Eouipment Drain Treatment System
~
VReactor coolant drain tank 2
350 gal WNS
, vfleactor coolant drain tank pump
- 7 100 gpa NNS Reactor coolant drain tank pump heat 2
NNS l
exchanger v Waste holdup tank 1-25,000 gal NNS
, ~ -
vWfsteevaporatorfeedpump 1
35 gpa NHS Waste evaporator feed filter 1
35 gpa NNS A ste evaporator' package 2
15 gpa NNS -
't Yaste evaporator condensate domineralizer 1
- p ? Aft, NNS
'Afaste evaporator condencate tank filter 1
35 gpa NNS
~
vWaste evaporator condensate tank,
2 10,000 gal NNS Waste evaporator condensate tank pump 2
35 gpa NNS Alaste evaporator concentrate tank 1
5000 gal NNS Xaste evaporator concentrate tank pump 2
T5 gpa NNS Floor Drain Treatment System Floor drain tank 4
25,000 gal NHS 4 oor drain tan'k pump 4
35 gpa NNS l
or drain tank filter 4-35 gpa NNS loor drain ~ reverse osmosis unit 2-30 gpm NNS Floor drain reverse osmosis feed pump 2
'30 gpm NHS vWaste monitor tanks 2
25,000 gal NHS L Yaste monitor tanks domineralizer 1
50 ft3 NNS (30 gpm)
Waste monitor tanks pump 2
35 gpm NNS vChemical drain tank 2s 600 gal NNS Chemical drain tank pump 2
35 gpa NNS G
-g 10/26/83 11-8 5 HARRIS DRAFT SER SEC 11 l
~
1^
. - __, :L, --
6
-~
Table 11.3 (Continued)
- w.,
Capacity Safety Component Number (each) class Laundry and Not Shower Treatment System pMundryandhotshowertankpump aundry and hot shower tank 2
25,000 gal NNS 2
35 gpm NNS Urdundry and hot shower tank filter 2
35 gpa NNS sLdundry and hot shower R0. unit 1
30 gpa NNS Laundry and hot shower RO feed pump 1
30 gpa NNS Aundry and hot shower dominera112er 1
50 ft8 NNS (30 gpm) dreatedlaundryandhotshowertank 2
25,000 gal NNS tJreated laundry and hot shower tank pump 2
100 gpa NNS
.At0 concentrate tank 2
5,000 gal NNS
'4t0 concentrate evaporator feed pump 2
35 gpm NNS Ut0-concentrate package 2
10 gpm NHS -
RO concentrate evaporator distillate pump 2
20 gpm NNS
~
Secondary Waste Treatment System d;pt conductivity holding tank 3
15,000 gal NNS 4
conductivity holding tank pump 2
100 gpa NNS econdary waste. 61ter 2
100 gpm NNS t.Acondary waste domineralizer 2
70 ft3 NNS
(
4econdary waste sample tank 1
25,000 gal NNS L5econdary waste sample' tank pump 2
100 gpm NHS 41gh conductivity holding tank 1.
15,000 gal NNS t#igh conductivity holding tank pump
+3
- 4& gpa NNS t6econdary wasta evaporator package 2
15 gpm NNS befecondary waste c" ;c 2te concentrate tank 2
4,000 gal NNS M acondary waste evaporator concentrate tank 2
35 gpm NNS pump The,LWPS has been designed so that liquid wastes from the reactor coolant and its associated subsystems are separated into three main streams:
recyclable reactorgrade,nonrecyclable,andsecondarywaste.4)Therecyclablereactor-grade stream consists of tritiated wastes collected in the equipment drains. A
./
his stream is treated by tne equipment drain treatment subsystem. The non-recyclable equipment stream consists of nonreactor grade water sources and is collected and processed through either the floor drain treatment subsystem or L--
~
0, 10/26/83 11-9 5 HARRIS DRAFT SER SEC 11 Q
F
&bwe. bd*N'*) 0*Y t
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the laundry and hot s.hower treatment subsystem.
The secondary wast stream con-
' -sists of regenerant solutions from the condensate polishing system nd backflush
-~
u jr from the electromagnetic filters of the steam generator blowdown system and is collected and processed in the secondary waste treatme'nt subsystem.
g.,,5renb.
The systems described above are shared between the two h im isoor oram x
tt.. n i. a uw.j:' -~
+- " ~ -i., -.,t; tr n..ut.,
.,n ems are snared "d
ba+ r:c..-
on.d.
All e4heesis5med systems are single subsystems.
All releases are monitored before discharge to the cooling tower blowdown.
The discharge valve is interlocked with a process radiation monitor and will close automatically if the radioactivity in the liquid should exceed a predetermined limit or 4f the dilution flow afforded by the cooling tower blowdown falls below a preset va'lue;.~ Additional details on the liquid radwaste treatment system
~
follow.
Theequipmentdraintreatmentsubs[stemcollectsreactorgradewaterfromequip-f-
ment leaks and drains, valve leakoffs, pump seal leakoffs, tritiated water sources, and tank overflows. These wastes are collected in the waste holdup tank and then processed via filtration and evaporation.
After processing, these wastes are either sent to the reactor makeup water storage tanks or to the waste monitor tank for discharge or to the wM** M1d"n tank for additional. treatment.
The floor drain treatment subsystem collects and processes water from the floor drains of the reactor auxiliary building (RAB), fuel handling building (FHB),
waste processing building (WPB),& k areas (reactor makeup water storage and tan s
condensate storage tanks).
-d prt';..; c' th; b;t :h:;.
The waste is collected l
in the floor drain tank and processed by filtration and treatment in the floor l
l drain treatment subsystem RO unit and then collected in the waste monitor tanks.
From the waste monitor tanks, the wastes may be discharged to the cooling tower blowdown line, pumped to the condensate storage tank, recycled to the waste hoidup tank for treatment in the equipment drain treatment subsystem, or pumped directly to the waste processing system (WPS) waste evaporator for treatment.
The last route will be utilized when radioactivity levels are such that filtra-tion and RO are not ' sufficient to reduce.the radioactivity to acceptable levels.
- (%.
l l
10/26/83 11-10 S HARRIS DRAFT SER SEC 11 l
i
-.,,n_.. _ _....,
.,m,_
s The laundry and hot shower treatment subsystem collects inthefaundr shower taakQtergent waste fr<m the WPB, the FHB, and the The ap-
, N_ '
plicant expects this waste te ce of such quality that, treatment for removal of radioactivity will not normally be required.
However, if analysis indicates that treatment is required, this waste will be routed to the laundry and hot shower RO unit. The permeate from the RO unit will be passed through a dominer-alizer and then routed to the treated laundry and hot shower tank. The contents of this tank can be recycled for further treatment or discharged to the condon-sate storage tank.
f The secondary waste treatment subsystem is designed to treat wastes generated from secondary systems. This water will contain radioactivity only if primary-to-secondary leakage occurs in the steam generators. The secondary waste treat-ment subsystein consists of one subsystem to treat high-conductivity wastes and the other to treat low-conductivity wastes.
Low-conductivity wastes such as the backflush from the electromagnetic filters becKwad wa te
,f of the steam generator bl n y s g g th Q g.g.:. :03 r Ms from the
\\._,
condensate polishing systen are collected in the low-conductivity holding tanks.
g These wastes are filtered and passed through a desineralizar and then collected in the secondary waste sample tanks.
From the secondary waste sample tanks, the water is either recycled to the condensate storage tank, discharged to the cool-ing tower blowdown or to the neutralization basirs, or recycled back to the low conductivity holding tanks.
7,, g, p b,',,n evil %
The main source of high-con etivity wastes is the regenerant solutions from the adef a de-@e hiah-conductivity ollected in th condensate polishing systemt This waste is JL i
and the evaporator distillate dis-e holding tank end processed by ~an evaporator 4 y
charged to the low-conductivity system upstream'of the domineralizer.
From the domineralizer, treatment is the same as for the low conductivity subsystem.
floo< draws -
Drainage from the turbine building equipment drains and curbed area cil equip-g ment and floor drains below the operating deck,is collected in the industrial l
waste sumps c# the turbine building.
Drainage from drains below ground eleva-tion 'is collected in a condensate pump area sump. This sump and the industrial I
waste tumps dischcrge through a radiation monitor. The contents of these sumps l
10/26/83 11-11 S HARRIS DRAFT SER SEC 11
_..,,._.,,,m
,._,_,.__,,.,,...,~.m.-.,y,
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will normally go to a yard oil senar tor and then to the cooling tower blowdown.
If the monitor detects Mr. den;e}ryr.u un in the discharge from one of these pump
... r
~
n
~
..u thedischargewillbe[irectedtothelow-conductivityholdingtankfor treatment.
The secondary waste subsystem also. collects (1) the wastes from the chemical drain tank that are not sent to the solid waste processing system for solidiff-cation and (2) the concentrated wastes from the waste evaporator, the RO units, These wastes are collected in the RO con-and the secondary waste evaporator.
The distillate centrate tank and processed in the RO concentrate evaporator.
from this evaporator goes to the treated laundry and hot shower storage tank fo The evaporator concentrate goes to the waste evaporator concentrate discharge.
The
- tank for solidification or for treatment in the volume reduction system.
liquid' waste system consists of a number of cross-ties that allow alternative Further detail on the liquid waste treatment schemes to those discussed above.
system and these treatment schemes is in FSAR Section 11.2.
11.2.2 Evaluation Findings f
The staff's
, k..
The LWPS system was reviewed according to SRP 11.2 (NUREG-0800).
review considered the capability of the proposed LW"S to meet the anticipated demands of the plant as a result of anticipated opi. rational occurrences.
The potential consequences resulting from reactor operation have also been co sidered, and the staff has determined the concentrations of radioactive mater in liquid effluents in unrestricted areas to be a small fraction of the limits fr. Table II, Column 2 of Appendix B to 10 CFR 20.
The staff has also considered the potential consequences resulting from reactor l[
operation with 1% of the operating fission product inventory in the core b released tc the primary coolant and has determined that the concentrations o l'
radioactive materials in liquid affluents in unrestricted areas will be a small fraction of the limits of Table II, Column 2 of Appendix B to 10 CFR 20.
~
1 e.
i S HARRIS DRAFT SER SEC 11 10/26/83 11-12 lj]
ha r:q 3
"*v 7
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- As discussed in Section 11.1 of this SER, the staff calculated liquid effluents C'
using the GALE computer. program based on the treatment systems for liquid These source terms are in Appendix D of the Harris $M ents described above.
Environmental Statement (NUREG-0$9t).
The staff calculated the doses to offsite individuals utilizing the methodology of RG 1.109 and the liquid dispersion parameters calculated in accordance with RG 1.113, " Estimating Aquatic Dispersion of Effluents from Accidental and The staff Routine Reactor Releases for the Purpose of Implementing Appendix I."
has determined that the proposed liquid.radwaste treatment systems are capab of maintaining releases of radioactive materials in liquid effluents so that the calculated individual doses in an unrestricted area from all pathways of expo-sure are -lerts than 3 mrems to the total body and 10 mrems to any organ.
^
~
As noted in Section 11.1, the staff has calculated the release of radioactive materials in liquid effluents exclusive of tritium and noble gases and found it to be less than S Ci per year per reactor and the annual dose to any organ of
'~
an individual in an unrestricted area to be less than 5 millirems per year to Therefore, in accordance with the option to Section II.D of
(
from both reactors.
Appendix I as provided in the Annex to Appendix I of 10 CFR 50, the st that the liquid radwaste system is capable of reducing liquid radioactive effl ents to as low as is reasonably achievable (ALARA) levels in accordance with 10 CFR'50.34a, Appendix I to 10 CFR 50, and the Annex to Appendix I.
FouMEnvirone ntal Statement presents a comparison of the The Shearon fiar:is4 and Appendix I design objective doses with the doses with calculated for th liquid source terms and a comparison of the,RM 50-2 curie limitation with projected releases.
The design of the liquid radwaste system presented in the FSAR is diffe At the CP stage the steam that proposed at the construction permit (CP) stage.
Although no process treatment generator blowdown liquid was to be discharged.
system was proposed, the applicant made a commitment to install equi ble of reducing-the level of activity in the blowdown stream by a factor o The applicant has since decided to install an electromagnetic 3000 or greater.
filter to remove magnetite and other spinel type oxides that are magne y
S HARRIS ORAFT SER SEC 11 11-13 10/26/83 6.]
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~ 9
,C to remove a portion of-the noamagnetic particulates.
The filter is flushed and the water is collected jn the settling tank. The flush water is then pumped to the secondary wasta low-conductivity holding tanks.
The steam generator blow-down passes from the electromagnetic filter to the condenser.
The condensate polishing system provides some removal capability for radionuclides.
The staff has assessed the overall capability of the radwaste systems to process waste in the event of a single major equipment failure by a comparison of the design flows to the potential process routes and equipment capacities.
Based on this review, the staff has determined that the radwaste system will be ade-quate to process wastes.
The_ staff has. considered the capabilities of the proposed liquid radwaste treat-ment system to meet the anticipated demands of the plant as a result of anti-cipated operational occurrences and has concluded that the system capacity and design flexibility are adequate to meet the anticipated needs of the plant.
/~
The staff has reviewed the' applicant's quality assurance, provisions for the (v
liquid radwaste systam. the quality group classifications used for system components, and the se c design applied to structutes housing these systems.
The design of the sys m.3 and structures housing these systems meets the criteria
~
~ set forth in RG 1.143.
The staff reviewed the provisions incorporated in the applicant's design to con-trol the release of radioactive materials in liquids as a result of inadvertent tank overflows and concludes that the measures proposed by the applicant are consistent with the criteria set forth in RG 1.143.
l.
l 11.3 Gaseous Waste Management System 11.3.1 Summary Description The gaseous waste management systems include systems that treat the normal ven-tilation exhausts; the exhaust from the main, condenser mechanical vacuum pumps; and the gaseous wastes asiociated with degassing primary coolant, purging tha g-y i
10/26/83 11-14 5 HARRIS ORAFT SER SEC 11 i
i. _.....
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-volume control tanit, displacing cover gases, purging equipment, gas samp1 ng and analysis operations; and boron racycle process operations.
J Table 11.4 provides a listing of the various normal ventilation systems and the Additional details are provided type of treatment ass 3ciated with each system.
in Section 9.4 of the FSAR. If a generalization can be made regarding the nomal ventilation exhaus,t treatment systems, it is ti.at the exhausts usually.
flow through a medium efficiency filter, a HEPA filter, and.a charcoal adsorber.
The RAB normal ventilation system (RABNVS) filters air from the coatinuous con-tainment purge exhaust and from areas of the RAB that contain equipment essen-tial for the safe shutdown of the reactors including the CVCS chiller area,
~^
~48D-V aux 111ary bus area, areas containing nonessential equipment, and so forth This system exhausts to the vent stack on the roof of the RAB.
Normal ventilation system components at Harris Table 11.4 Filter Medium Demister Heater Filter HEPA Charcoal HEPA System
~'
X X
X RAB normal ventilation X
X WP areas filtered exhaust X
X X
WPB laboratory fume hood exhaust (except perchlorite)
X X
X Condensate polishing domineralizer area filtered exhaust apstem X
X X
X X
X Condenser vacuum effluent treatment
- l
)C X
X 1
l Continuous containment purge (passes through RAB normal ventilation system and airborne radioactivity removal system) l X
X X
Containreent pre. entry purge y*Willnotbeusedtofilterreleasesonaroutineeasis;creditwasnotgiven
((
v in the Appendix I evaluation.
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S HARRIS DRAFT SER SEC 11
%y 11-15 hj 10/26/83 h
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e-f The waste processing areas filtered exhaust system exhausts air from the con-
' aminated areas of the WPB and discharges to a vent stack on the roof of the t
WPB.
The WPB laboratory areas fume hood exhausts are, filtered except for the perchloric acid exhaust. This exhaust is discharged unfiltered to the vent stack on the roof of the WPB.
The air from the contaminated spaces of the condensate polishing domineralizer area is exhausted through the condensate polishing domineralizer area filtered exhaust system.
The exhaust is discharged from the vent stack located on each unit's turbine building.
The conden gs r vacuum pump effluent treatment system is discussed in Section in.a.2 of MESER..
The containment pre-entry purge is filtered by the containment pre-entry purge system. The purge is discharged to the RAB vent stack.
Additional details of the normal ventilation systenfare in Section 9.4 of the FSAR.
(?
(. '
The gaseous waste processing system (GWPS) processes gases collected from the E
volume control tank and vent eaneet4ene from the recycle evaporator gas stripper, the reactor coolant drain tank, the pressurizer relief tank, and the recycle holdup tanks.
The GWPS is shared between the two units and consists of 2 waste gas compressors, 2 catalytic hydrogen recombiners, and 10 waste gas.
decay tanks to accumulate the fission product gases.
Eight gas decay tanks are used during normal operation, and two are used for shutdown and startup.
Nitrogen with entrained fission gases will be continuously circulated around the GWPS by one of the two waste gas compressors.
Fresh hydrogen gas is charged to the volume control tank where it is mixed with fission gases that have been stripped from the reactor coolant into the volume control tank gas space.
The contaminated hydrogen gas is continuously vented from the volume control tank into the circulating nitrogen stream to transport the fission gases into the GWPS. The hydrogen-nitrogen mixture of fission gases is pumped by the waste gas compressor to the hydrogen recombiner where the recombiner converts the hydrogen to a water vapor by oxidation.
After removal of the vapor, the result-
~
ing gas stream'is circulated-to a waste gas decay tank and then back to the 10/26/83 11-16 S HARRIS DRAFT SER SEC 11
q 6
/^
compressor.
Each gas decay tank is valved into the GWPS recirculation loop for 1 or 2 days.
Continued plant operation results in the buildup of pressure in the waste gas decay tank because of the accuelation of nonremovac,1e fission gases. When the pressure in the gas decay tanks reaches 25 psig, the alignment of the GWPS must be changed because of the design of the recombiner.
The new alignment has flow from the compressor to the gas decay tanks to the recombiner and then back to the compressor. This alignment is suitable for operation up to 100 psig.
The GWPS has analyzers to monitor oxygen concentrations between the oxygen supply and the hydrogen recombiner package and downstream of the recombiner.
Hydrogen analyzars.are located in the process stream entering the recombiner and in the discharge stream from the recombiner.
The app 11 cant has indicated that the normal ventilation system complies with the criterir of RG 1.140 and that the GWPS conforms to the criteria of RG 1.143.
f 11.3.2 Evaluation Findings The gaseous waste management system was reviewed according to SRP 11.3 g _9,n At the CP stage the offgas from the condenser air ejectors was untreatedqnd, g
except for the exhaust from the WPB, the ventilations systems were only filtered l
by HEPA filtars. The WPB exhaust was also filtered by a charcoal adsorber. The staff stated in the SER-CP that treatment of the main condenser offgas would be required to reduce this potential source of iodine-131 to the atmosphere to j
bring the offsite doses into compliance with Appendix I.
The applican gad j
l addedthecondensereffluenttreatmentsystem,whichcanbeutilize(during 2rt rm i
pa n s e.
I conditions of high radioactivity from the. mechanical vacuum pump, and has added g
charcoal adsorbers to the various ventilation systems that exhaust air from l
contaminated areas.
These additions decrease t.he quantity of iodine released l
from Harris and are.therefore acceptable when, judged against the design objec-tive doses of Appendix I to 10 CFR 50.
However, it should be noted that the lh k
10/26/83 11-17 5 HARRIS DRAFT SER SEC 11 4
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~- -
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staff did not credit the plant with comevet of' the condenser effluent because gl the condenser affluent. treatment system will not be utilized on a routine basis.
The staff has calculated the doses to individuals off site utilizing the meth-odology of RG 1.109 and the atmospheric dispatrsion parameters calculated in accordance with RG 1.111, " Methods for Estimating Atmospheric Transport and i
Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors. " The staff has determined that the proposed gaseous radwaste treatment systems are capable of maintaining releases of radioactive materials in gaseous effluents so that the calculated individual doses in an unrestricted area from all pathways of exposure are less than 5 mress to the total body and 15 mress to any organ from noble gases and that releases of radiciodine and radioactive material 10 particulate fom result in doses that are less than 15 mreas to any organ.
The staff has also considered the potential effectiveness of augmenting the pro-posed gaseous radwaste treament systems using items of reasonably demonstrated
(
technology. The applicant has chosen to show compliance with Section II.D of
'v Appendix I to 10 CFR 50 by complying with the Annex to Appendix I (RM S0-2).
Tne Harris Environmental Statement presents a comparison of the doses and releases calculated for Harris 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, the staff has determined that no further effluent treat-ment _ 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. The staff has determined that the conentra-tions of radioactive materials in gaseous effluents in unrestricted areas will be a small fraction of the limits of Table II, Column 1 of 10 CFR Part 20.
~
The capability of the proposed gaseous radwaste. treatment systems to meet the anticipated demands.of the plant as a result,of operational occurrences was also considered, and it was concluded that the system capacity and design flexibility
(.
are adequate to meet the anticipated needs a$stupassues of the station.
10/26/83 11-18 5 HARRIS DRAFT SER SEC 11
6,
~
visions for the gaseous raowaste systems,
- 7
_The, applicant's quality assurance pro the quality group classsifications used for system compcnents, the seismic design applied to the systems, and the structures housing the,radwaste systems were The FSAR indicates that the design of the systems and the struc-also reviewed.
J~..,
tures housing these systems meet the criteria set forth in RG 1.143.
th; p';..; b now wwn.ic."; s.uolu.,
L..,..a one wmpres wi..nu wo. p.
J. e.
,w.i Jn.Ay te,,L.
O ch
- ...ip.ur is required in accorcance wi o aar amnyzers ari rwyuired
--ile M 3 The staff has reviewed the normal ventilation system design, testing, and main-The appli-tenance of the HEPA filters and charcoal adsorbers against RG 1.140.
cant has indicated in FSAR Chapter 1 that the normal ventilation system meets the riteria.of. This guide.
I C.
A Tht(
ove informa on 1 required, al g with commitm t th the app cant w th i tall du analyzer befor he staff ca co lete its evaluacion of he GWPS.
11.4 Solid Waste Manaoem:at Systems 11.4.1 Summary Description The solid waste processing system (SWPS) is designed to process two general Wet solid wastes types of solid wastes: wet solid wastes and dry solid wastes.
consist mainly of spent filter cartridges, demineralizer resins, filter sludges, chemical drain solutions, and evaporator bottoms that contain radioactive mate-rials removed from liquid streams during processing.
Dry solid wastes consist mainly of ventilation air filtering media (HEPA, charcoal), contaminated c
clothing, paper, rags, laboratory glassware, and tools.
The spent filters associated with the various ventilation systems will be moved l
from the filter housing, wrapped, and packaged from disposal using a hydraulic The filter sluges from the liquid radwaste systems will be back-
' compactor.
washed to a WPB filter backwash storage tank and to the WPB paticulate concen-These sludges may then be sciidified or sent to the volume reduc-4 Ms.
trate tank.
l-Chemical drain solutions will be seidiN d.M 7
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tio stem.
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p 5 HARRIS DRAFT SER SEC 11 11-19 10d /83 c
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1A/SCd 3 c l The dry. salt generated'by operation of the volume reduction system will be N
collected i,n a storage hopper.
When a sufficient amount of material has been collected to require solidification, the salt is transN ered to a drum for solidification by the use of a polymer.
Compressible low-activity solid waste will be compacted in 55 gallon drums.
The' compactor is equipped with a hood, ventilation fan, and HEPA filter. The displaced air will be vented through the HEPA filter.
The applicant has indicated that the storage capacity of the SWPS is 1020 drums.
Theg pplicant has also indicated tht the SW35 meets the criteria of BTP u m&-
ETSg, Revision 1,whichistheequivalenttoRG1.143.
q The applicant has committed that all radicar.tive waste will be packaged in ac-cordance with appropriate Federal and state standards for burial in accordance with 49 CFR 170 to 179, 10 CFR 20, and 10 CFR 71.
All drums will be shipped and buried in accordance with 49 CFR 173.
/-
Additional infonsation with respect to the solid radwaste system is in Section 11.4 of the FSAR.
11.4.2 Evaluation Findings The staff has reviewed the SWPS in accordance with the ccceptance criteria of SRP 11.4 (NUREG-0800).
The scope of the review included line diagrams of the system, piping and instrumentation diagrams and descriptive information for the SWPS and for those auxiliary supporting systems that are essential to the opera-tion of the SWPS.
The applicant's proposed design criteria and design bases for 4nd the applicant's analysis of those criteria and bases have also the SWPS been reviewed.
Also reviewed were the capability of the proposed system to process the types and volumes of wastes expected during normal operation and anticipated operational occurrences in accordance with GDC 60 and provisions for
-the handling of wastes relative to the requirements of 10 CFR 20 and 71 and ap-3 plicable Department'of Transportation regulat, ions h m -:':: t:r ::.ic :d.
t a
10/26/83 11-20 5 IIARRIS DRAFT SER SEC 11 7-
~
0
,. 4 J 5 - W -
C The taf wil. no a rove the'd gn f the SW un il the ant p 1 es k
in armati det ling w var us waste om nents are ated.
In. rmation th t is mis
- includes es t1
.4 Q&
dw -f+uw d.U,,M w - F.<.a a jd on how the filter sludge # :: t b fc,11c :.
i;'. crs will be handled, rd...d.6/ drawings M b
& n. y -q ur~a w M &
A:
reactorcoolank seal water injection seal water return
.. _. boric acid.
BRS recy'cle evaporator feed BRS recycle evaporator concentrate t'
recycle evaporator condensate
'g g
e b
b
&./A y M.
/
(3 de ils showing th th. vent exhaust f the spent re n stor et and t.
decanti tanks a filter y a HEPA fil in accordance with BTP ETS 1-('SRP 11.4) w The applicant ha indicated that portions of the RAB that have piping systems that could contain stagnant boric solutions are equipped with space heaters or are. heat traced to ensure that temperatures >70*F are maintained during operat-A ing modes 1-5.
The applicant did not specify what raeansg
- be4Hy utilized for a
the concentrates line of the recycle evaporator to the boric acid tank.
^
+'~1 f It s the staff's sition that boric acidhlutions should be iraintained at Crystalizabn would not 170* for all modes o operation, not just mod 1-5.
be a f ction of the op *ating mode.
In addition the applicant did ot'specify what mea were utili2ed ensure that the piping stems are maintain d at 170*F for ose portions of he RAB for which space he ters are utilized.
Some automatic me s should be ava able to start the heaters hen the temperatu approaches 70 Therefore, it 's the staff's position tha the applicant shculd specify what pa meters are monit ed to result in automatic itiation of these b
L heaters.
10/26/83 11-21 S HARRIS DRAFT SER SEC 11 k
i b
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. [.
fA The applicant has not provided the process control program (PCP). The PCP is not required until 6 months before the issuance of the operating license.
The PCP will be judged as to its acceptability when it is submitted.
N A>e 11.5 Process and Effluent Radiolocical Monitorino and Samolino Systems 11.5.1 Summary Description The process and effit[ent radiological mor.itoring and sampling systems are designed to provide information concerning radioactivity levels in systems throughout-the plant, indicate radioactive lethage between systems, monitor equipment and performance, and monftor and control radioactivity levels in
, plant discharges to the environs.
The Harris airborne affluent sampling and monitoring systems are located in the plant vents on the RAB and the WPB.
For liquid effluents, the affluent monitor s -
locations are downstream of the pumps of the LWPS waste monitor tanks, the treated laundry and hot shower tanks, and the secondary waste sample tanks.
Effluent monitors are also located to monitor of the industrial waste sumps of 1
the turbine buildings, the discharge from the tank area drain transfer pumps, and the service water system.
~
Table 11.5 contains a listing of both the process and effluent monitors for air-borne and liquid sources.. For ease of reference, this table also includes the type of radioactivity monitor for airborne effluents, the type of monitor used, and the plantM pecifie, number of the monitor. Sections 11.5 and 12.3.4 of f.
the FSAR present a detailed discussion.of the process and effluent monitoring system.
11.5.2 Evaluation Findings The staff has reviewed the process and effluent monitoring system according to SRP 11.5 (NUREC-0800).
10/26/83 11-22 S HARRIS DRAFT SER SEC 11 e
-.m
- - - - = = - - - --
--e-------
5
- i..
s
- t Acceptance Criterion II.C.1.a of SRP 11.5 states that the gaseous and liquid U
process streams and effluent release points should be monitored and sampled.
according to Tables 1 and 2 of SRP 11.5.
Information provided in FSAR Sec-tion 11.5 indicated that the SHNPP did not meet these criteria in the following areas:
(1) The turbine gland seal condenser exhaust and the mechanical vacuum pump exhaust /are not monitored and sampled in accordance with Table 1.
dxreg k'3mg iPtra b5 dutr$
(2) The condenser vacuurpump effluent /s not sampled in accordance with
.64 y rN3 ptM Table 1.
(3)-There-is,no effluent moni r for the turbine building vents (release points 3A and 3B) as required by Table 1, and sampling provisions are not provided.
YQ yw$rsi.Toduseisn-t.
(4) The service water systemg i.I 5: monitored downstream of all inputs to A
the system. The liquid monitor for the emergency fan coolers Me not ade-quate for Ud. H[;rb..S Of'/'" "'
D
_p m
[ The applicant has indicated, in response to a staff question, that the process andeffluentmonitoringprogramwillmeettheguidelinesofpositionCofRG4.15,\\
The applicant has not addressed the capability of the process and effluent 8
toring program to meet the guidelines of position C and Table 2 of RG 1.97. p The
)
applicant has addressed item II.F.1, Attachments 1 and 2 of NUREG-0737, which covers criteria for effluent monitors similar to those proposed by RG 1.97.
Based on the staff's review of the applicant's g i g g he staff has concluded that the applicant has incorrectly located two inonitoring points. The turbine i
l g
building effluent release points, 3A and 38, shoulci be points of monitoring and not the condenser vaccum pump effluent point alone. This change would'(1) result f
in the monitoring of a potential effluent release source (condensate polishing cubicles) wMe4 is excluded by the present moni.toring scheme; (2) allow isokinetic samples to be taken;.(3) and minimize the potential damage of high humidity air, 1
on the sampler's charcoal adsorber. Th: ;;;'j :;.a
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se -
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Z AJ !<txt i b t-l 1 26/83 11-23 5 HARRIS DRAFT SER SEC 11 I
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Table 11.5 Liquid and airborne process and effluent monitoring q..
system at the Shearon Harris Nuclear Powcr Plant Monitor Monitor Monitor number Monitoring
- type Airborne Process g
Gas decay tank 21RDI-3545 NG p scin FHB normal exhaust
%1FL-3506 P, I, NG S scin, y scin, jl(-1FL-3507 p sein FHB emergency exhaust
$ 1FL-3508BSB P, I, NG S scin, y sein, E scin M FL-3508ASA E scin, y scin, p sein RAB normal exhaust R M 1AV-3531 P, I, NG ~
p scin,.y scin, E sein
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~
lplG2AV-3531 P, I, NG p scin, y scin, E sein RAB emergency exhauct htkM-1AV-3532A P, I, NG S scin, y sein, i
I p scin RI M-1AV-35328 P, I, NG S scin, y scin, p sein R M-2AV-3532A P, I, NG S scin, y scin,
(
p sein L
R EP2AV-3532B P, I, NG S scin, y scin, 4
s sein Condenser vacuum pump
- C41TV-353/,
NG S sein effluent treatment id!Me2TV-3534 #
NG S sein system Continuous containment O'1LT2002hA T, I, NG S scin, y sein, purge I
p scin i
Rl' -ILT-3502pSB P, I, NG S scin, y scin, E scin R'
2LT 2 M2?i^
, !, t'G S sein, y scin, "k
p sein E+2LT-3502fSBP, I, NG
$ scin, y scin, s sein
/
e Liquid Process Component cooling water 1 Rett-3501A ta y scin system e IREM-3501B 56 y sein r 2 Rett-3501A 54 y scin
~
i2 REM-3501B 2 y sein ALI.cc y
- P = particulate; I = radiciodine; NG 4 noble p,ases.
10/26/83 11-24 s HARRIS DRAFT SER SEC 11 l
g s
--.L. 7 Table 11.5 (Continued)
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Monitor Monitor Monitor number Monitorin'g*
type 21R$3525A 8
y sein Auxiliary steam con-densate tank f245"-??50-m y scin Steam generator
% d GM-3527 y sein blowdown Q23527 Auxiliary steam con-21TH;M-3543
.y sein
%nsate waste Ac processing system y sein WPB cooling water 1RfM-3544 WG irborne Effluent g
Plant vent (Release G Mi-35095A P, I, NG S scin, y scin, vv p sein l~ Point'1)r REM-2.9llf-35095A P, I, NG
$ sein, y sein, p sein f
WPB exhaust systems
]
(ReleasePoint5) 85W1W-3546 P, I, NG S scin, y scin, E sein
/
(' '
(ReleasePointSA) %W-3547 P, I, NG S scin, y sein, A sein 4 _.
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Turbine building vent stack (ReleasePoint3A I (Release Point 38)
Liquid Effluent
~ ~ ~ ~ ~ ~
" ~ ~
Servicewatefs'yiiem
-1SW-3500ASB y sein y scin R -25W-3500ASB y sein R
1SW-3500BSA y sein R -25W-3500BSA y sein 4-1SW-3500CSA y sein
-25W-3500CSA F
y sein
]
-1SW-3500DSB y scin g
-25W-35000SB
[
I Waste monitor tanks
$21WLW41 y sein y sein I.
Turbine building drain Reft-1MD.3528 y scin 1
RSPt-2MD-3528 y sein l
Tank area drain W 1MD-3530 y scin
-transfer pump 7t1M-2MD-3530 y sein Treated laundry.and W1WL-3540 hot shower tank numps y sein l;
Secondary waste sample EBt21WS-3542 tank pumps a
l; 10/26/83 11-25 S HARRIS ORAFT SER SEC 11 j
'\\
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~
C' The applicant has proposed a method for determining the release of radioactivity
\\
from.the safety relief walves and the atmospheric steam dump valves '. hat is similar to that proposed for the Waterford plant.
The. staff is assessing this method at this time.
Based on the determination made in the Waterford review, the ac:eptability of the method proposed for Shearon Harris will be the same.
The applicant cannot ensure representative samples from the recycle holdup tank because the capability of the recirculation pump es not meet the criteria of II.2.a of SRP 11.5.
Therefore, the applicant ch:1.gproposet.analternative means of ensuring that the contents of the various liquid waste may be sampled in a representative manner.
MMTb
&&54 Ann +hae - n ;' t.%.ssyt....
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...a ef !*'o " * * "t he applicant has e f
- ddn a.m Oi.i u,;.f i. um.... oc.r...c.
. ::..... is the incorporation of v.
administrative controls and procedures to minim inadvertent or accidental
~
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releases of radioa t iquids.
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~
The turnine builcing drain monitors and the tank area drain monitors do not provide a record of effluent flow. Therefore, there appears to be no means. c b/
to n,* p determine the quantity of activity released nor the volume,rele g +n n.-d-anee-+4sa RG 1.21.
It is the staff's position that Harris (post.ess the capabil-ity to determine the quantity of effluants released from these two sources.
The applicant has agreer to divert waste from the industrial waste sump and the tank area to a radwaste treatment system upon detection of radioactivity.
This C w n "'b satisfies the staff's concern.
of b resp ses to staff questions the SAR, the ica t must As a esu re se Tabl 9.3.2-2 igure 9.3.2 2, and.S wion 9.3.2.
2 to.eflect gr b s mpling of t say ice water system.
The staff's review of the process and effluent monitoring system has not addressed some items of SRP 11.5.
Those items that have not been addressed will be reviewed when the Radiological Effluent. Technical Specifications are reviewed.
Those areas of the process and effluent monitoring system to be reviewed at that time include 10/26/83 11-26 S HARRIS DRAFT SER SEC 11 I
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-(1) sampling frequencies, required analyses, instrument alarm / type setpoints,
~ - -( '
calibration, and sensitivities (2) frequency of routine instrument calibration, maintenance, and inspections The process and effluent monitoring systems cannot be judged as y
P[ Y M'
- 4 _
, until the above item,s f re addressed M S
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11-27 5 HARRIS DRAFT SER SEC 11
.1 10/26/83
'a b
I 11.1.2 Harri t Insert A pg 11-7 While the applicant assumed that the VR system would be treating filter sludges, the staff could not accept this. The fluidized bed dryer of the VR system was not intended to treat filter sludges. There' would not be much, if any, VR associated with this form of treatment of the sludge. In addition, with the' typical radioactivity associated with filter sludges, the potential exists that Appendix I doses could be exceeded. Additional details concerning this are addressed in Section 11.4 of this SER.
Insert B pg 11-19 The applicant did not have an 0 monitor on the discharge from the GWPS com-2 pressors. This did not conform to the acceptance criteria of SRP 11.3.
In addition, the applicant did not have a system designed to preclude the buildup of explosive H and 0 mixtures through automatic isolation of the 2
2 0 source.
Idea 111y, system design should ensure that (1) the valve in the 2
line from the 0 supply fails closed automatically on a high-high alarm; 2
(2) that if the downstream 0 concentration exceeds 4%, flow is automatical-2 ly switched to the alternate recombiner; and (3) if the 0 e ncentration 2
exceeds 4% in the part of the GWPS between the compressor and the gas decay i
tanks, automatic control features exist to reduce the 0 concentration by 2
l the injection of diluents.
The applicant has added an 0 m nitor between the compressors and the gas 2
decay tanks.
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(Insert B pg 11-19 continued)
At the Harris plant, the only automatic function the GWPS has is to isolate the 0 supply to the recombiners ' hen a high 0 concentration is detected w
2 2
in the recombiner exhaust.
If this occurs, an alarm will sound at the waste process control board, which is manned continuously.
The applicant has committed to establishing the set point for the 0 monitor 2
on the compressor to alarm at 2% 0. This alarm will occur at the waste 2
^
processfng c~ontr'o1 board and, when such an alarm occurs, personnel will verify the alarm and that the component, which is the source of the inleakage, will be removed from service.
f The staff finds this approach acceptable in lieu of having automatic control
\\
features since the actions will be precipitated at 2% 0 rather than at 4L 2
The action items of the technical specifications covering these monitors will be' written to show automatic isolation of the 0[sourcion a signal
~
~
~~
~
of 2% 0 in the recombiner exhaust and that a signal of 2% 0 from the 0 2
2 2
monitor on the GWPS compressor, the affected component will be removed from service. These measures are adequate to prevent the occurrence of an explosion.
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Insert C pg 11-19 Based upon the foregoing evaluation, the staff concludes that the proposed gaseous radeiste treatment syst'em is acceptable. The bases for the accepta-nce has been the conformance of the applicant's design, design criteria, and design bases for the gaseous radwaste treatment system to the applicanble rregulations and Regulatory Guides referenced above.
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Insert D pg 11-20
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l The VR system consists of a fluidized bed dryer which is utilized to calcine evaporator bottoms (conc 6ntrates) and chemical drain solutions. The liquid to be calcined is collected in the waste feed solidification pre-treatment tank where the pH is adjusted. The contents of this tank is pumped to the venturi scrubber of the VR system where it is utilized to scrub the offgas from the gas / solids separator of the VR system. The scrub solution is con-centrated in the scrubber pre-concentrator and recycled to the venturi. A portion of the concentrates from the pre-concentrator is used as feed to the fludize bed dryer.
In the fludize bed dryer, mos3 of the liquid is calcined as salts.on the bed material. This bed material is discharged from the dryer and conveyed to the solidification system for drumming. The offgas from the fluid bed dryer is discharged to a gas / solids separator where the large particulates are removed. The solids collected from the gas / solids separator are collected in a hopper and conveyed to the drumming station.
The offgas from the gas / solids separator proceeds through the venturi scrubber, the scrubber pre-concentrator, a condenser, to a gas heater and finally through a filter assembly consisting of a HEPA filter, charcoal adsorber, and another HEPA filter.
9 4
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Insert E pg 11-21 The appl cant has recently purchased the polymer binder system for solidifi-cation c the dry salt material. A description of the polymer binder system has not een provided. However, the applicant has committed to providing details n the system as they become available.
Information on this system will be onsidered a confirmatory item. The applicant has in.dicated t. hat q
- the poly er binder system will conform to SRP 11.4 (continue on pg 11-21)
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4 Insert F pg 11-21 The applicant has exmitted to heat tracing with temperature monitoring the
~
concentrates line fr::m the recycle evaporator to the boric acid tank. The 0
temperature will be maintained to a low setpoint of 70 F and high setpoint cf 90*F with redundant thermocouples and panels for all operating modes (1-6).
A combination of space heaters and heat tracing will be used for other lines
' -ca'rrying 5 h.' boric acid. The temperature monitoring for the lines with dedicated heat tracing will be the same type as stated above for the concentrates line. For the areas in which space heaters will be used, auto-matic temperature monitoring (area thermocouples) will be used to insure that the space heaters are started at a low setpoint temperature of 70 F.
This will be for modes 1-6.
This satisfies a previous staff concern.
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E Insert G pg 11-22 The applicant has indicated that they intend to process filter sludges in the VR system. This is unacceptable to the staff. The VR system design, which was approved by the NRC (December 1,1975 AECC-1), was not based upon processing filter sludge. The topical report on the VR system did not provide any test data on the processing of this waste.
In addition, the VR system was never intended for such processing. These would be little, if any,
_ VR associa.ted.with such processing and with the activities typically associated with such sludge the releases could be at a level such that Appendix I dose limitation may be exceeded. Therefore, approval of the VR system is contingent pon the applicant agreeing not to process filter sludge in it.
e e
6
.: V
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%wiTy s
4 6.
ETSB compares the quality gro'up classificatio.
of the solid waste system
. ' ~ '
to the guidelines of Regulatory G*uide 1.14V(Ref. 2).
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ETSB compares the seismic design of t structures housir.g the SWS,,to the guidelines of Regulatory Guide 1.14 Ref. 2).
Exceptions are fransmitted toMEB/whichhasprimaryrespons ility under SRP Section 3 J.1.
designfeatures,andmode-lofoperationof
/
8.
ETSB compares equipment layo the solid waste system to e guidelines of Regulato uide 1.143
'(Ref. 2) and (BTP) ETSB 3 (Ref. 1).
/.
9.
At the OL stage ETSB eviews the technical specf ications proposed by the
~
applicant for proc s and effluent control fp[ input to the review of SRP Section 16.0.
T reviewer will determine that the content and intejit'of it of the staff's review,ement he applicant are in agre the technical ecifications prepared b The with the re rement developed as a r review wi include the evaluation development of appropriat6 limiting conditi s for operation and thei bases consistent with the plant design.
The t nical specifications ar reviewed per the requirements of 10 CFR Par 0,, 95,0.36a (Ref. 4).
/
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~
IV. JVALUATION FINDINGS
' ETSB verifies that suf fic nt information has been provided and that the deview is adequate to s port conclusions of the following type, to be
/ included in the staf f's safety evaluation reon"-
[
1 : -- ' : m
- f that the design of the solid waste management systems
(
is acceptable and meets the requirements of 10 CFR Part 20, 520.106;
[
10 CFR Part 50, 550.34a; General Design Criterion 60, 63, and 64; and
'~
10 CFR Part 71. This conclusion is based on the applicant demonstrating j
that the solid waste system (SWS) includes the equipment and instrument-i
/
ation used for the processing, packaging, and storage of radioactive wastes prior to shipment offsite for burial. The scope of the review of f
the SWS includes line diagrams of the system, piping and instrumentation diagrams (P& ids), and descriptive information for the SWS and for those auxiliary supporting systems that arc essential to the operation of the I
SWS. The applicant's proposed design criteria and design bases for the
/
SWS, and the applicant's analysis of those criteria and bases have been reviewed. The capability of the proposed system to process the types and
[
volumes of wastes expected during normal operation and anticipated opera-tional occurrences in accordance 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, and the applicant's i
quality group classification and seismic design relative to Regulatory Guide 1.143, hwe also been reviewed.
The pp"c:-t': p epr:r
-+Ws d
af a""d ag cr ;i;;; a,1 k'i fic" ?:
ud,':- drat: * ; S. L,,
.. i:wed ivoi1re> ano
.ns 2: :;: ::t S :n.o T m unical e d th; pc;,..~ ;.3, m.wn P= 4+4aa m ' 11-2 rd :"" R e,;n 11."
A m. _ ;, (oyrii l ls - M anis
,tec;;; of 1 l..:1
- d';;;ti.
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The basis i.dth tampor; g -,its for acceptance in :;r c;.i;w has been conformance of the applicant's designs, design criteria, and design bases for the solid radwaste system to the regulations and the guides referenced above, as well as to staff
>f technical positions and industry standards.
On;d :r t": '"^f'2 C
rerl;;tien, __ ;;n:1 C th:t tF: p g.;,-J ;;iid :d c ; :./ *^= is M W df
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11.4-5 Rev. 2 - July 1981 l
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Insert I pg 11-23 l
The applicant has committed to installing a wide range noble gas monitor for withdrawing samples from the. turbine building vent stack during normal operations and accidents. This monitor will also be provided with con-tinuous sampling capability for radioactive particulates and iodine. The monitor sampling line will be heat traced to prevent moisture accumulation in the. particulate and iodine filters. This commitment satisfies the NRC concern identified as Item 3 above.
The applicant has comitted to routing the turbine gland seal condenser exhaust to the turbine building vent. This eliminates one part of Item (1) above of noncompliance. With the installation of the continuously sampling
(~
system on the turbine building vent, the eff.luent from the condenser vacuum Y'
pump is sampled continuously. This eliminates Item 2 above.
As discussed in Section 10.4.2 of this SER, the applicant still does not have any means for continuously sampling for particulates and radioiodines during hogging operations nor is the applicant capable of determining noble gas releases from this source. This item is open.
The applicant has not addressed Item 4 above to the satisfaction of the staff so that it too is an open item.
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Insert J pg 11-26
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The applicant has proposed that a representative sample of the recycle hold-up tank can be accomplished by recirculating the tank, taking samples from the tank; and trending the sample results. Since the purpose of sampling the tank is to determine whether the fluid is s'uitable for recycling, this determination can be made without absolute knowledge of the boron recycle tank's contents. Therefore, a " leveling off" of sample results is not requi red. Since the contents of this tank cannot be released directly to the environment,' the staff finds this acceptable.
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.Ill.D.1,1 Integrity-of Systems Outside Containment Likely to Contain Radioactive Material I
Summary Description The applicant has providad a description of the program designed to reduce leakage from systems -cut:"? ::-t:" 9t that would or could contain primagcoolant ora /$4Y $
highly radioactive fluids during a serious transient or accident.Q;..:
- ,,,.,1 ;....;
c,a J t;.s amma wnich woulo De inuuceu in v.ne teat recuction program anc tnose h-;;h w old 5; ; ni ded. Tha :ppli c:r.t '. c . i us a-.. ',;d t ;.m e.y.;m ou.cuuw=
kakage-te c= -i vw-o. e.aw..
- l e. '.. g. i v. iv wwercial operat-ion arm th
- p r^g r !-
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te-fvilG i crc 0 20- :Fri:1 ;;;r;ti;F hegin3.
Evaluation and Findings The staff reviewed the applicant's prcposed program to reduce leakage from systems containing primary coolant or highly radioactive fluids outside containment in
~
s accordance with Item
~.1.1 of NUREG-0737. Based upon this review, the staff has concluded that the applicant's program does not meet the requirements of NUREG-0737.5::r e (1) The gaseous waste processi systera (GWPS) was excluded from the program.
Thi system should not be exclu from the program.
Sources to this system include venting operations from the ele holdup tank, reacto coolant drain tank, s es izer relief tank, volume cont 1 tank purge, and the re le evaporacor stri e r.
l (2) The process sampling stem should not be excluded the program since it l
is designed to collect f d and gaseous samples containe n the reactor
~
coolant system and the safety 'njection system.
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9' Thedem\\
inetalizers of the CVCS shoul e included in the program since they (3)
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-may be utilizc" during RHR operat n.
(4) The boron recycle
- ponents, ich should be included in the program, are the recycle evaporator ee umps, recycle evaporator feed filters, and demineralizers. Since t
n to the baron recycle system would pass through the filters d the de 'nerclizers and since the feed pumps would have to be utili d to pump the co tents from the recycle holdup tank,'all
_ three compone s should be included i tnc
' gram.
(5) The seal w er return systein should not b ex
'+d from the program, since it is d.irable to have the reactor coolant p ps gerating during a steam gener ter tube rupture accident and the seal wate return system would be i
o rating during such an event.
[l (6) The applicant has not provided the justification for exclu ng those systems U
which could contain radioactive materials.
The applicant should modify their proposed leak reduction program to include the above systems or components in the leak reduction programsruu 34. w i s. ;ci t.Lc r
.j.usM i ka i. i on r or uvi ou. n3 Z h r :;:*
- ' i A.J....'..J. I:AR ~
- wn auwa caa aur g w, 4._
e
' The applicant shall also provide the initial leak-test results at least four
. conths prior to issuance of a fuel loading license.
L.
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... e Insert K III.D.1.1 x
The applicant's program will be initiated during the preoperational test phase and will be performed in accordance with the applicable provisions of ASME Section XI. The program is designed to detect leakage to RAB atmosphere from systems which would be used to bring the plant to a safe shutdown following a serious transient or accident. The following systems are included in the leak reduction program.
a)
Residual Heat Removal System; b)
Safety-Injection System, except boron injection recirculation subsystem; c)
Containment Spray System, except spray additive subsystem and RWST; d)
Chem. cal & Volume Control System; 1)
Letdown Subsystem Except Demineralizers 2)
Boron Recycle Hold-Up Tanks
,e 3)
Chorging Pumps-V.
e)
Post-Accident Sample System; f)
Post-Accident RAB Ventilation System; and g)
Valve Leakoff Equipment Drain System.
The following systems have been excluded by the applicant frr the leak
~
reduction program because they will not be used to mitigate the censequences of an accident:
a)
Chemical and Volume Control; 1
Domineralizers Boron Thennal Regeneration System 3
Seal Water Return 4)
Boric Acid Transfer System 5)
Boron Recycle System Except Recycle Holdup Tanks b)- Safety Injection; 1)
Baron Injection Recirculation Subsystem c)
Filter Backwash System;
=
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. Insert K III.D.1.1 '.s?:
d)
Fuel Pool Cooling and Cleanup System; e)
Radioacti,ve Waste Disposal Systems; and f)
Frocess Sampling System.
The applicant's leak reduction program will employ visual inspections of the mechanical joints and seals of the system to detect leakage and measurement of observed leakage. These inspections will be conducted with the system pressurized to normal operating pressure using the system fluid or deminerallied water as a test medium. The applicant will document the observed leakage and will compare it against the acceptance criteria.
Corrective action will be taken as appropriate, but, in in11 cases, the action will be to reduce le'akage to as-low-as-practical levels. Testing of gaseous s'ystems 'will include helium leak detection or equivalent testing methods.
The applicant will initiate a program of preventative maintenance to reduce leakage to as-low-as-practical levels after commercial operation. This program will include periodic leak tests at each refueling.
The applicant has evaluated potential leak paths as discussed in NRC letter regarding the North Anna incident dated October 17, 1979, and has committed to implerienting design changes, if the need is identified prior to fuel load to eliminate the open paths to the atmosphere as discussed in the letter.
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Insert L III.D.I.1
^
C The applicant has restricted the program to only those systems in the RAB and only those systems which are used to bring the plant to a safe shu~tdown following a transient or an accident. The systems which are to be included are systems outside containment that would or could contain primary coolant or other highly radioactive fluids or gases during or following a serious transient or accident. Therefore, limiting this program to systems utilized to bring the plant to a safe shutdown following an accident or a transient is an incorrect. interpretation of this item, and in the case of Harris systems should not be limited to those in the RAB.
The applicant has excluded the gaseous waste processing system (GWPS). The applicant's basis for excluding this system is that since the system operates
(,
continuously the integrity of the system is continuously verified through the use of airborne radiation detectors.
- An alarm from one of these monitors
- =M rquire prompt isolation and repair of that portion of the system that is leaking.
.The staff does not agree with the applicant's position. If the fuel failure
[
1evel is low, then a leak from the GWPS would never result in an alarm from l-this airborne radiation monitor. The leak reduction program would see this l
. sooner than the monitor in this case.
In addition, from the Harris FSAR, there are no airborne radiation monitors in the areas of the GWPS. Thus, this GWPS should be included in the leak reduction program.
G I
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n
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Insert L III.D.I.1 ~ -
y The boron recycle system (BRS), except for the recycle holdup tanks, has been excluded from the leak reduction progrca because the applicant con-sidered this tank to be the only component of the system that would be required and this system performs no safety-related functions following an accident. The applicant stated that if the feed pumps and feed filters were
-required post-accident then the system could be leak-tested before its use and repairs made. This basis is unacceptableito the staff.
First, the requirements of III.D.1.1 are not limited to safety-related systems. Second, the time to leak test the feed pumps and feed filters is not after an accident has occurred, but rather before. The recycle
,e evaporator feed pumps are utilized to transfer the contents of one recycle k
holdup tank to another and should be included in the program. The recycle
. evaporator domineralizer and the feed filter should be included in the pro-(
gram since the normal flowpath is through these components.
The filter backwash system was excluded by the applicant because they indicated that the filters would be bypassed during letdown to the recycle holdup tank. That possibility does exist but there are a number of other filters which must be considered. They include seal water injection and return filters and reactor coolant filters. The filter backwash system should be included in the leak reduction program.
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Insert L III.0.1.1 2-se..
The applicant has excluded the seal water rer en because this system is not used post accident and because it discharges its centents to the pressurized surge tanks on a Phase A containment isolation signal (T signal).. The staff agrees with this. However, if the accident which occurs is a steam generator tube rupture with a coincident iodine spike, then it is desirable to have the reactor coolant pumps operating and the seal water return would also be operating. No Phase A signal would result. Therefore, the seal water return shou]d be included in the leak reduction program.
The applicant has also excluied the fuel pool cooling cleanup system. This system is utilized to maintain fuel pool temperature and to remove particulate f-material from leaking or defective fuel assemblies. This system would be s-..
operating during a fuel handling accident. In addition, the purification system will be started on a high radiation alarm in the fuel handling building. Therefore, this system should be included in the leak reduction program.
The applicant has also deleted the CVC5 demineralizers from the leak reduc-tion program: However, these demineralizers are used during cold shutdown and RHR operation.
Bypass flow from the RHR system is admitted into the letdown line upstream of the letdown heat exchanger, flows through a mixed bed demineralizer and the reactor coolant filter to the volume control tank.
Again, these demineralizers should be included in the progrem.
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