ML20087N220
| ML20087N220 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/30/1984 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20087N221 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 3F0384-11, 3F384-11, NUDOCS 8404030233 | |
| Download: ML20087N220 (13) | |
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March 30,1984 3F0384-11 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NUREG-0737, Item II.B.3 Post Accident Sampling System (PASS)
Dear Sir:
As requested in your letter of July 12,1982, and confirmed by our letter of July 30, 1982, Florida Power Corporation is submitting the attached responses to document how we have satisfied each criteria of NUREG-0737, item II.B.3 and three (3) sets of drawings which are referenced throughout the submittal.
If you have any questions, please contact this office.
Sincerely,
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t G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management EMG/feb Attachment cc:
Mr. 3. P. O'Reilly f
1 Regional Administrator, Region II
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,}if Office of Inspection & Enforcement h
U.S. Nuclear Regulatory Commission P
101 Marietta Street, N.W., Suite 2900 (k
Atlanta, GA 30303 gf GAM g
8404030233 840330
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, /> I PDR ADOCK 05000302 F
F PM GENERAL OFFICE 3201 Thirty-fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733
- 813-866-5151
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CRYSTAL RIVER UNIT 3 l
ATTACHMENT TO LETTER DATED 3/30/84 NUREG 0737, Item II.B.3 POST ACCIDENT SAMPLING SYSTEM (PASS)
- Criterion'(1):
The licensee shall have the capability to promptly obtain reactor coolant samples and containment atmosphere samples.
The combined time allotted for sampling and analysis should be 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or less from the time a decision is made to take a sample.
Criterion (1)
Response
(1)
The 'CR-3. Post Accident Sampling System (PASS) is a remotely controlled and. monitored sample delivery system with on-line ' isotopic and chemical analysis monitors and installed provision for obtaining multiple grab samples for off-site analysis verification. The delivery system consists of: 1) a liquid system for, obtaining high pressure Reactor Coolant System (RCS) samples from either. (a) normal letdown, (b) normal
- pressurizer gas, (c) normal pressurizer liquid, (d) emergency cold leg "A" loop. or (e) emergency cold leg "B" loop, or low pressure L
samples from (a) reactor building sump, (b) decay heat loop "A",
(c) decay' heat loop "B", or (d) miscellaneous warte storage tank.
- The sample recirculation return may be directed back to ehher (a) reactor building sump, (b) miscellaneous waste storage tank, or (c) makeup tank (the makeup tank return is intended only for high pressure-RCS samples prior to chemical analysis).- The above' samples are cooled by an automatic temperature control system.and reduced in pressure by automatic pressure control 1
valves prior to grab samples and chemical analysis monitor.
inlets. This system is shown on DWG. FD-318-700.
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(2) A gas system for obtaining Reactor Building (RB) atmosphere samples from.(a) the' RB: dome area, (b) the emergency RB recirculation duct, or (c) the normal RB recirculation duct. This system also - has the capability of sampling either plant ventilation release points (RB purge duct or Auxiliary Building exhaust duct). The sample recirculation' for the RB atmosphere samples are returned to the RB, and -the ventilation system samples are returned to the Auxiliary Building exhaust duct. The
. above samples are not - conditioned prior to on-line isotopic analysis or grab sampler inlet. This system is shown on DWG.
FD-318-693,694, and 695.
The calculated recirculation time required to obtain a representative sample at the applicable analyzers assuming 2 volume changes in the sample system under' minimum sample flow rates are:
a)
Normal letdown without MU system flow (0.25 gpm 2 hr. 56 min.)
b). Normal pressurizer steam or water (not applicable to post-accident sampling) c)
Emergency cold leg "A" loop (0.25 gpm 7 min.)
d)
Emergency cold leg "B" loop (0.25 gpm 11 min.)
e)
f)
Decay heat loop "A" (0.25 gpm 6 min.)
g)
Decay heat loop "B" (0.25 gpm 6 min.)
h)
Miscellaneous waste storage tank (0.25 gpm 4 min.)
.1) - RB atmosphere dome (0.2 ACFM 17 min.)
'j)
RB atmosphere emergency recirculation duct (0.2 ACFM 3 min.)
k)
RB atmosphere normal recirculation duct (0.2 ACFM 4 min.)
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RB purge exhaust duct (0.2 ACFM 1 min.)
m). Auxiliary Building exhaust duct (0.2 ACFM 1 min.)
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The time required to perform on-line analyses are listed individually, however, the system is configured such that they can be performed concurrently.
AIMS Liquid (30 min.)
- Boron Liquid (30 min.)
Chloride Liquid (30 min.)
Dissolved Hydrogen Liquid (estimated at 60 min. with present configuration when operable) - see Criterion (4) response AIMS Gas (30 min.)
The above times for obtaining a representative sample combined with the performance of on-line analyses are well within the required three-hour time requirement except for the letdown sample (item a) which is for normal operation sampling. The item (a) recirculation time can be reduced by increasing the
- sample flow to a maximum of.5 gpm which will then allow this sample and analyses to be completed within the three-hour requirement.
The power required for PASS equipment operation is from Engineered Safeguards Supplies (diesel generator backed) or from DC supplies (battery backed). In addition, the computer and instrument panels are supplied through an uninterruptable power
- supply.
Criterion (2):
I The l'icensee shall establish an onsite radiological and chemical
. analysis capability to provide, within the three-hour time frame 1 established above, quantification of the following:
e (a) certain radionuclides in the reactor coolant and containment atmosphere that may be indicators of the degree of core damage (e.g., noble gases; iodines and cesiums, and non-
- volatile isotopes);
(b)_ hydrogen levels in the containment atmosphere; 3
(c) dissolved gases (e.g. H ), Chloride (time allotted for analysis 2
subject' to discussion below), and boron concentration of liquids.
(d) alternatively, have in-line monitoring capabilities to
- perform all or part of the above analyses.
Criterion (2)
Response
The CR-3 PASS utilizes the on-line monitoring approach of item (d). For discussion of eq'uipment capabilities, see Criterion 10.
Reliability and maintenance discussion:
AIMS - Automatic Isotopic Measurement System is a second
' generation development based upon previous systems supplied for continuous fission product analysis in CANDU reactors.
The detector assembly is designed so that the system can function in an accident environment while sensitive computer components are located in an air-conditioned cabinet in the count room.
1 Boron & Chloride - The Boron and Chloride analyzers were
. supplied by NUS, who-has extensive experience in the development _ of procedures' and equipment to meet the regulatory requirements for post-accident sampling and analysis.
In fact, the NRC requirement for matrix solution qualification of all PASS instruments is based on a-research and development program' performed by' NUS in 1980 for. Commonwealth Edison Company, and others. All instruments offered by NUS are fully qualified for post-accident and normal operation use, and several
.are presently in service at operational plants.
.NUS provided an lonics automatic titration instrument for boron analysis and ai Dionex lon chromatograph is used for Chloride
. analysis.' Both instruments are custom-modified by NUS for post-accident use, and have been fully qualified using a matrix solution.- Each instrument has a history of reliable service in many industrial applications.
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- Dissolved Hydrogen' - The installed system for dissolved hydrogen measurement consists of the introduction of Nitrogen stripping gas into the cooled and depressurized sample stream which then passes through a static mixer that enables a homogeneous stream to enter the phase separator. In the phase separator, the sample is' separated into liquid and gaseous portions. Gases are drawn
.off-the phase separator by a gas pump through a Leeds and Northrup Thermal Conductivity Gas Analyzer and a Flo-Tech Turbine Flow Meter.
The liquid leaves the phase separator through another Flow-Tech Turbine Flow Meter and on to the NUS analyzers. The determination of Hydrogen concentration is performed by the computer based upon the Hydrogen analyzer concentration, gas flow rate (corrected to STP), and the liquid flow rate. Functional testing of this system' has not provided consistent results in the low concentration ranges because of problems with'the Hydrogen analyzer and non-linearity of the gas flow meter.
Because' of these accuracy problems, this system was not declared operable; however, the monitor system modifications to correct these problems are under evaluation.
See Criterion 4 response.-
Reactor Building Hydrogen - Provisions for Hydrogen monitoring of the RB is provided under NUREG-0737,' Item II.F.1.6.
The system is a full safety grade system dedicated to H2 monitoring only, using redundant Teledine monitors with dual sample points.
' The system is capable of providing Hydrogen indication within 30 minutes after an accident. See FD-318-693.
A formal procedure for estimation of core damage is presently based upon~ a Plant Procedure which uses inside containment radiation monitor readings.
Determination of damage based upon PASS ' readings can be provided by the Nuclear Fuel
- Management as required by the Emergency Coordinator utilizing the methods described in NUREG/CR-2507 titled " Background and Derivation of ANS-5.4 Standard Fission Product Release Model".'
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Criterion (3):
Reactor coolant and containment atmosphere samp!!ng during post accident conditions shall not require an isolated auxiliary system (e.g., the letdown system, reactor water cleanup system (RWCUS)) to be placed in Operation in order to use the sampling system.
Criterion (3)
- Response:
' The CR-3 PASS does not rely on auxiliary systems which are
' isolated as'a result of an accident to be placed in service. The chemical analysis section of PASS uses a phase separator to remove dissolved gases from the sample before analysis. These gases are presently. returned to the waste gas compressor suction for transfer to the waste decay tanks which can be transferred
~ to the RB.
This method of: stripped gas disposal under an
- accident situation is under evaluation in order to determine if it could be sent directly back to the RB. Unaccessible valves which are critical to system operation 'are qualified for the environment to which they would be exposed.
Criterien (4):
Pressurized reactor coolant samples' are not required if the licensee can-quantify the amount of dissolved gases with unpressurized reactor _ coolant samples.
The measurement of either total dissolved gases or H2 gas in reactor coolant samples is considered adequate.- ' Measuring the 02 concentration is
~ recommended, but is not mandatory.
-Criterion (4) iResponse:
The -installed PASS 1 equipment for ' monitoring dissolved RCS Hydrogen concentrations ~ has not been declared operable because of-problems. associated with the analyzer.
A replacement monitor has been ordered and 'a -detailed evaluation of all installed H2. equipment. is underway to'. identify any potential
. problems with' the design prior to installation of the replacement monitor. Thisl effort is intended to preclude any further delays
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~ in providing an acceptable dissolved Hydrogen monitor.
The schedule for 'this activigy will be available by 6/1/84.
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w At this time, the ' capability to monitor dissolved Hydrogen in the RCS is provided by the interim system installed under NUREG-
-0578.
Criterion (5):
The time for a Chloride ~ analysis to be performed is dependent upon two factors: (a) if the plant's coolant water is seawater or brackish water and (b) if there is only a single barrier between primary containment systems and the cooling water. Under both of the above conditions'the licensee shall provide for a Chloride analy' sis within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the sample being taken. For all other cases, the licensee shall provide for the analysis to be completed within 4 ' days. The Chloride analysis does not have to be done on-site.
Criterion (5) -
- Response:
For discussion of time..'to perform a Chloride analysis, see Criterion ! response.'
' Criterion (6):
~ The design basis for plant equipment for reactor coolant and containment atmosphere sampling and analysis must assume that It is possible to obtain and analyze a sample without radiation exposures to any individual exceeding the criteria of GDC 19 (Appendix A,-10 CFR Part 50), i.e., 5 rem whole body, 75 rem
' extremities)... (Note that the design and operational review Criterion was changed from the. operational limits of 10 CFR Part 20 (NUREG-0578) to the GDC 19 Criterion (October 30,1979 letter from H. R. Denton to all licensees).
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Criterion (6) :
Response::
The design criteria for the PASS included the prevention of radiation exposures to individuals from exceeding GDC 19 (App.
A,10CFR, Part 50). The dissolved Hydrogen monitoring system design is under evaluation as discussed in Criterion (4). This evaluation will review the drain. trap in the gas system for 7c
L.
shielding ' enhancements.
The exact predicted personnel exposures. based ' on person-motion studies have not been completed at this time. The schedule for this activity will be available by 6/1/84.
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- Criterion (7):..
The analysis of primary coolant samples for boron is required for P'WR's. (Note that Rev. 2 of Regulatory Guide 1.97 specifies the need for primary coolant boron analysis capability at BWR r
plants).
Criterion (7)
Response
This capability is provided, See Criterion ! response.
Criterion (8):
If inime monitoring is used for any sampling and analytical capability specified.herein, the licensee shall provide backup sampling through grab samples, and shall demonstrate the L
capability of analyzing the samples.~ Established planning for analysis at offsite facilities is acceptable. Equipment provided for backup sampling shall be capable of providing at least one
. sample per day for 7 days following onset of the accident, and at least one sample per week until the accident condition no longer exists..
- Criterion (8)
Response
Back-up grab sampling capability is provided for both the liquid and ; gas L sampling systems.
Extra shielded containers are 1 provided such that while samples are in transit to the established
~
. off-site laboratory (Oak Ridge) the required daily samples can
,.7 still be obtained to meet the one sample per day criteria.-
1 Criterion (9):
The ' licensee's radiological and chemical sample analysis capability shall include provisions.to:
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(a) Identify and quantify the isotopes of the nuclide categories discussed above to levels corresponding to the source terms i
given in Regulatory Guide 1.3 or 1.4 and 1.7.
Where necessary and practicable, the ability to dilute samples to provide capability for measurement and reduction of personnel exposure should be provided. Sensitivity of onsite liquid sample analysis capability should be such as to permit measurement of nucilde concentration in the range from approximately 1 micro curie / gram to 10 curies / gram.
(b) Restrict background levels of radiation in the radiological and chemical analysis facility from sources such that the sample analysis will provide results with an acceptably small error (approximately a factor of 2).
This can be accomplished through the use of sufficient shielding around samples and outside sources, and by the use of a ventilation system design which will control the presence of airborne radioactivity.
Criterion (9)
Response
The CR-3 PASS is an on-line monitoring system. See Criterion 10 for nuclide identification discussion.
- Criterion (10):
Accuracy, range, and sensitivity shall be adequate to provide pertinent data to the operator in order to describe radiological and chemical status of the reactor coolant systems.
Criterion (10)
Respon_se:
Gross activity, gamma spectrum: The AIMS provides realtime Isotopic analysis of liquid or gas samples with a range of 10-4 to 107 microcuries/mi and an accuracy within a factor of 2 for the isotopes of concern, i.e., noble gases, lodines, and non-volatile radionuclides.
Boron.- Modified Ionics automatic titration with range up to
' 6000 ppm and accuracy of + 5%
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s Chloride'- Modified Dionex lon chromatograph with range up to 20 ppm and accuracy of + 10%
pH - Same device as Boron instrument with range of 1 to 13 units and 'an accuracy of +.3. units.
The initial test of the pH determination did not yield this accuracy with an acceptable confidence level.
Subsequently, a component modification appears - to-have corrected the problem.
However, further testing will be performed to verify its performance.
Dissolved Hydrogen - Details of this analysis will be provided upon operability of the N2 monitoring system. See Criterion 4 response.
The Boron and Chloride units were on-site tested for acceptance using the Standard ^st matrix provided by NUS (excluding Gamma Radiation).
b
-A prototype of the AIMS was performance tested by the vendor.
These. tests successfully demonstrated its functional abilities.
- The detector used was a 500 mm2 by 10mm thick high purity
- planar germanium detector.
The counting efficiency results show that under normal background conditions-that a range of
. measurement for both liquid and gas samples from less than 10-4 to greater than 107 microcuries per ml. can be readily achieved
- for an 88 kev gamma-ray emitting nuclide using a 1000 second counting time. An equally wide sensitivity range can be realized at higher gamma-ray energies.
The effectiveness of the AIMS shielding design for both natural background and elevated background was - measured.
Under
' natural background conditions, the counting rate is extremely
- low with only-about one count per channel per 1000 seconds in
- the 80 kev spectral region and even fewer at higher energies.
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The background was also measured with a cesium-137 source external to the detector shield. This 250 mR/h exposure rate on the outer shield surface increased the background count rate to only about 10 counts per channel per 1000 seconds at 80 kev and only 15 to'tal counts per 1000 seconds in _the 662 kev photopeak were measured.
Extrapolation of this data, along with the realization that under abnormally high background conditions, the samples are also more active, supports the position that the AIMS will be able to function satisfactorily in radiation fields exceeding 100 R/hr.
Criterion (11):
In the design of the post accident sampling and analysis capability, consideration should be given to the following items:
(a) Provisions for purging sample lines, for reducing plateout in sample lines, for minimizing sample loss or distortion, for preventing blockage of sample lines by loose material in the RCS or containment, for appropriate disposal of the samples, and_ for flow restrictions to limit reactor coolant loss from a rupture of the sample line. The post accident reactor coolant and containment atmosphere samples should be representative of the reactor coolant in the core area and the containment-atmosphere following a transient or accident.
The sample ' lines should be taken from containment. The residues of sample collection should be returned to containment or to a closed system.
(b) - The ventilation exhaust from the sampling stations should be filtered with charcoal absorbers and high-efficiency particulate air.(HEPA) filters.
Criterion (11)
Response
Purging - The capability to purge the liquid sample system with
' demineralized water is provided as shown on FD-318-700.
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r System procedures provide for purging the system following each'
- sample in order to minimize plateout and reduce area dose rates
-in the event maintenance is required.. The RB sump sample is.
also capable' of being back-flushed to the sump to - remove blockage caused by loose material in the' sump. The gas sample system also has provision 'for purging with instrument air as shown ' on FD-318-694.
In addition, the gas sample lines are provided with low point drains to return any condensation back to the containment. The gas sampling procedures also provide for purging following each sample in order to minimize plateout and reduce area dose rates in the event maintenance is required.
. The gas sample system has not been provided with heat tracing, howeveri a detailed review of the system as-build configuration is. under. way in order to. determine the necessity for heat tracing. The schedule for this evaluation will be available by 6/1/84.
Both the liquid and gas sample systems have the capability of
- multiple sample points which provides flexability and increases the system reliability for sampling under various accidental conditions.
The ventilation from both liquid and gas grab sample stations are routed to the Auxiliary Building system which is subsequently routed through charcoal absorbers and HEPA filters before
. release.
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