ML20096A725
| ML20096A725 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 08/24/1984 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 9114N, NUDOCS 8408310226 | |
| Download: ML20096A725 (27) | |
Text
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s Commonwealth Edison.
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) one First Nationil Pen. Chic:g7, !!hnois
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) Address Reply to: Post Office Box 767
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,/ Chicago. Illinois 60690 August 24, 1984 Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission l
Washington, DC 20555
Subject:
Byron Generating Station Units 1 and 2 Braidwood Generating Station Units 1 and 2 Volume Reduction System NRC Docket Nos. 50-454/455 and-50-456/457 Reference (a):
July 19, 1984 letter from L. N. Olshan to D. L. Farrar.
Dear Mr. Denton:
This letter provides additional information regarding the l
volume reduction systems at Byron and Braidwood stations.
NRC review of this information is necessary to close Outstanding Item 15 of the Byron SER.
l l
Enclosed with this letter are responses to the NRC questions transmitted in reference (a).
They have been assigned l
FSAR question numbers 321.75 through 321.99 and will be included in the FSAR in the next amendment.
One signed original and fifteen copies of this letter and the attachments are provided for NRC use.
If you have any further questions regarding this matter, j
please contact this office.
Very truly yours, l"3.
A L-t.
R T amm Nucl ar Licensing Administrator im 9114N YA*El%"Potte8%
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B/B-FSAR
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.c QUESTION 321.75 e
"How will CECO 6d6ure that the quantity of halogenated
. plastics in the"fedd to the incinerator is limited to
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1% by weight and the heat rate is" limited to 700,000 Btu /hr?"
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RESPONSE
' CECO w'$11 institute a set of controls to limit the amount of halogenated plastics that will be processed in the dry waste. processor.
They may. include
/
Sorting wd'std[before it is processed to remove PVC a.
for compaction.
b.
. Procurement controls may also be used; however, the use of PVC in the plant will not be eliminated.
The feed rate of combustible materials to the dry waste pro-cessor is adjusted to maintain the excess oxygen content in the dry waste processor at approximatel'y 10% to 12%, as recorded on O R107.
This corresponds to 700,000 Btu per hour heat relc$se rate since the air flow rates to the dry waste processor are controlled or regulated to maintain a uniform gas velocity in the vessel.
High;and-low oxygen; concentration alarms are provided.
The operator can adjust the-trash feed rate by using controllers.SC '26 or SC 127;to adjust speed of the trash feed s6rews.
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.B/B-PSAR QUESTION 321.76 "How will CECO limit the concentration of sulfur to 1000 ppm and chlorides to 5000 ppm in the incoming ~ dry active waste and the sulfur concentration in contaminated oil limited?"
RESPONSE
The waste oil will be sampled and analyzed for sulfur periodi-cally.
Sulfur and chlorides in the dry active waste will be controlled by the methods discussed in the response to Question 321.75.
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j B/B-FSAR QUESTION 321.77 "How is. CECO anticipating decontaminating the trash hoppers (H-3A and H-33) ?"
- RESPONSE Decontamination of the trash hoppers (OVR08TA and OVR08TB) can be accomplished as follows:
a.
. Screw conveyor operable - Screw conveyor transfers-trash-to a container for temporary storage.
The residual material is removed by a' vacuum creating device.
The interiors of the trash hoppers are then manually cleaned.
- b. - Screw conveyor inoperable - The trash is removed by a vacuum creating device.
The interiors of the trash hoppers are then manually cleaned.
' CECO has experience with vacuuming as a decontamination process.
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B/B-FSAR~
-QUESTION 321.-78 "What type of training has been provided to CECO in e
preparation of the operation of Volume Reduction (VR) system?
Was training provided on a prototype unit, full scale-model, or a simulator?"
RESPONSE
Formal training was provided by AECC personnel at the site and some CECO personnel have visited the prototype facility.
The. training program was videotaped for future use.
No simu-lator training was used.
Additional training will be provided by AECC personnel during the startup and checkout testing of the system when simulated waste will be used in the system at-the Byron Station.
Redundant crew backup training will be provided during operation of the system by CECO.
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-a, B/B-FSAR QUESTION ~321.79
" Regulatory Position 1.2 of Regulatory Guide 1.143,
. October 1979, discusses the requirements to prevent uncon-trolled releases of liquids.
Items discussed include level indicators, alarms, and routing of spills to the liquid radwaste system.
Based upon a visit to Byron, neither the design nor the as-built system seemed to comply with these requirements, e.g.,
contaminated oil storage tank.
The system design and the as-built system at Byron should be modified to. comply with this regulatory position, and CECO should review the design and the as-built system to ensure that it conforms to the regulatory position of this regulatory guide."
RESPONSE
A review of the design of the volume reduction system shows that it conforms to Regulatory Position 1.2 of Regulatory Guide 1.143, October 1979, with the following exceptions:
a.
Those exceptions listed in Topical Report No. AECC 2-P(NP) including amendments.
b.
No high level alarm has been provided for the contam-inated oil tank (OVR04T) because the switches that allow the tank to be filled are mounted locally and it requires approximately 2 minutes to fill the tank.
c.
No high level alarm has been provided for the flush water recovery tank (OVR09T).
The high level switch starts the flush water recovery tank pump (OVR30M).
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B/B-FSAR
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QUESTION'321.80
" Address the radioactivity associated with contaminated oil which will be incinerated."
RESPONSE
CECO experience from the Zion Station shows that between 800 and 1200 gallons / year of contaminated oil may be produced and.thi oil.will contain activity ranging f rom 1 x 10 " to
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1 - x' 10 Ci/gm.
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B/B-FSAR CUESTION 321.81-
"It'is the staff's position that decontamination solutions containing organics should not be processed in evapor'ators
- unless the plant has a chemical oxygen demand' monitor (COD).- The reason being that, in the past, the decontam-ination solutions sent to various radwaste treatment systems' have been recycled.to reactor water storage tanks.
When
- the-organics made it into-the reactor, the organics decom-posed and played havoc with reactor instrumentation, e.g.,
incidents at the Brunswick and Hatch plants.
CECO should-address how they'will nandle.the. decontamination solutions associated with the VR system."
RESPONSE
CECO does not plan to use organic decontamination solutions for the VR system.
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B/B-FSAR
-QUESTION 321.82
'" Discuss differences in the Byron /Braidwood-VR system
- design ~ compared to.that' contained in the AECC-2-P(NP)
- topical report.
Explain.the reason for the dif ferences in the design."
RESPONSE.
'See the-response to Question 321.15.
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B/B-FSAR QUESTION 321.83 "Your FSAR for Byron /Braidwood discusses the plant's conformance to Regulatory Guides 1.140, 1.1.43 and 8.8.
From some non-conforming items identified in your VR system design,-it.is not clear.whether the conformance addressed in the FSAR included the VR system.
Identify those areas of the VR system which do not conform to
~ these regulatory guides."
RESPONSE
-The design of the volume reduct' ion system conforms to Regulatory Guides 1.140, 1.143, and 8.8 with the following exceptions:
a.
The 0-15 psig tanks were designed, fabricated, inspected and tested per the requirements of ASME Code Section VIII, Division 1, including the ASME Code Stamp.
See the answer for Question 79 tx) Topical Report No.
AECC-2-NP, Amendment 2 for further information.
b.
tk) provisions have been made to route spills of con-taminated oil to the liquid radwaste treatment system.
See the answer for Question 55 in Topical Report No.
AECC-2-NP, Amendment 2.for further information.
The contaminated oil tank does not have a high level c.
alarm.
See the response to Question 321.79 for further information.
d.
Compliance with Regulatory Guide 1.140 is discussed in Questions 63 and 80 in Topical Report No. AECC-2-NP, Amendment 2.
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-'QUESTIO'N 321 84~
" Discuss ~ the' conformance of the 'VR -system solids product to meet the. requirements of 10 CFR Part 61-and.the-branch
' technical position. papers on waste. form:and waste classification."
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- RESPONSE See-'Dow Topical Report DNS-RSS-200 (June _ 26, 1984).
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B/B-FSAR QUESTION 321.85 "It-would -appear that a high level alarm should be included on_the contaminated oilfstorage tank.
The high level alarm-would prevent potential spills."
RESPONSE
A high' level switch has been installed on the contaminated oil tank.
It causes the tank's inlet valve to close and the feed pumps,tx) stop when it is activated.
Also see the answer
'for Question 55 to Topical Report No. AECC-2-NP, Amendment 2 for further information.
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B/B-FSAR-QUESITON-321.86 "Shouldn't the. valve in the vent line from the waste liquid storage. tank to the auxiliary building filtered vent header be-in the open position and not closed, as shown in sheet 33 of drawing'M-48?"
-RESPONSE Yes..
The-?&ID will be revised to show these vent valves as normally open.
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B/B-FSAR QUESTION 321.87 "Shouldn't the flow rate to the secondary scrubber and the AP across the scrubber be part of the instrumentation information av~ilable to the VR system operator?"
RESPONSE
- Secondary ' scrubber performance;is a function of the pressure -
drop across the scrubber-unit.
Therefore,_ the AP across the secondary scrubber is : indicated by PDI 310 The-flow rate can be. adjusted to maintain the AP across the scrubber.at 60 inches water column, via a hand operated throttling valve.
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'i, B/B-FSAR QUESTION 321.88-
"Why'does a portion of the exhaust flow from the gas / solids separator sent directly to the portion of the scrubber preconcentrator above the mist eliminator?"
RESPONSE
All exhaust flow from the gas / solids separator goes directly to the venturi scrubber preconcentrator.
There may be some confusion on instrumentation lines running to the AP cell denoted as PDTSAHL 67 (Reference FSAR Figure 11.4-7, Sheet 2).
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Q321.88-1
'B/B-FSAR QUESTION 321.89 "The flush water recovery tank should meet the requirements of Regulatory' Guide _l.143.
Does this tank meet these requirements?a RESPONSE.
The flush water recovery tank (OVR09T) meets the requirements of Regulatory Guide 1.143 except the high level switch does not actuate an alarm; however, it does-start the flush water recovery tank pump OVR30M.
Provisions for indicating this pump's operation have been installed.
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B/B-FSAR
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QUESTION 321.90 p
in drawing M-48,
" Inlet -air filters L (OVR0 3M and OVRO 2M) m sheets 34.and 36 contains no
'P instrumentation to inform 1 he' operator that the filter is clogged or that there tis no flow lor reduced flow. ' This filter should contain
.such' instrumentation."
RESPONSE
Both' of these filters are expected to operate about 3,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.befo're plugging.
These filters will be visually. inspected and serviced-by washing during the VR system's annual main-tenance..In the worst case, if the filter did plug, the system would. safely : shut down on loss of gas flow or low pressure.
The filter could then be changed _and the system restarted.
It takes about 1/2 hour-to service the blower inlet filters.
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i B/B-FSAR QUESTION-321.91
' "For what'paramater does the metal detector alarm high?"
RESPONSE
The metal detector can detect metal-objects as small as a single metal staple.
The unit is equipped with adjustable sensitivity level.
The detector measures a change in the flux-density of an inductive coil as determiaed by a change in current when metal is present.
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t-B/B-FSAR QUESTION 321.92 "What type'of instrumentation is contained on the trash
' shredder filter-to. indicate that it is plugged?"
RESPONSE
No instrumentation'is provided since this filter can be visually inspected at the inlet shredder hood and readily replaced if required.
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QUESTION-321.93 "What variable. is AERSAL 75C monitoring in the vessel i
- head of the dry waste processor?
Is it density?"
' RESPONSE Instrument AERSAL 75C monitors oxygen.
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- QUESTION 321.94 "Does"an alarm occur on a high or low AP across the scrubber preconcentrator?":
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RESPONSE
Alarms for' both high.and low AP across the scrubber precon-
- centrator occur..
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.q QUESTION 321.95
' "Why are;there two different density'(?)-monitoring elements with alarms on the recirculation line from the scrubber / pre--
concentrator recirculating pipe?"
RESPONSE
Instrument AERAHL 66c monitors. density and pH.
See Topical Report No.' AECC-2-NP, Amendment 2, Volume Reduction System P&ID.
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. QUESTION-321.96 "Why would the material from the-bed storage and transfer hopper of the dry waste processor.have~'the contents of its bed transferred ; to : the hopper associated with the
- fluid bed dryer when these'two vessels utilize entirely
- different bed material for the two processes?"
' RESPONSE-The material from bed storage and transf er hopper. (OVR06T) is transferred-to the-fluidized bed dryer (OVR01D) for disposal.
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B/B-FSAR QUESTION 321.97 "What parameters are monitored in order to ensure that the-gas / solid separator is working correctly?"
RESPONSE
Pressure drop, flow rate, and gas temperature are monitored to ensure proper operation as follows:
- Pressure Drop - The AP transmitter (PDTSAH 71C) located across the gas / solids separator is connected to a high alarm in the control room.
The high alarm indicates plugging of the unit.
Flow Rate - The inlet flow rate to the gas / solids separator is indirectly controlled by controlling the inlet _ flow rates to the fluid bed dryer vessel (OVR01D) and the dry waste pro-
.cessor vessel (OVR035).
The fluidizing air flow rate to the fluidized bed dryer is controlled via PTRSAHL 72A, the elbow air flow rate to the fluidized bed dryer is controlled via FITSAL 72E, and the fluidizing air flow rate to the dry waste processor is controlled via FIRSALH 73D.
These ' low rates cce alarmed in the control room.
Temperature - The dryer outlet gas temperature is controlled via TWERAHL 71C 'and the dry waste processor outlet gas tem-perature is controlled via TEWRCSAHL 74.
Both temperatures are alarmed in the control room.
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B/B-FSAR QUESTION 321.98 "It appears that, in portions of the VR system, there is insufficient instrumentation on various components of the system to~ provide the operator of the VR system adequate details on the status of these components.
Some of this is because the instrumentation is monitored locally with no input-to the VR system control room.
In other cases there is no monitoring at all.
EY.amples where flow indication in the control room.would provide useful infor-mation include:
(a) waste recirculation pump; (b) contaminated oil pump; (c) service air to fluid bed dryer; (d) flush water recovery tank pump (no indication of flow at all) ;
(e) booster blower (no indication of flow at all).
"The filter, OVRO 8F, sheet 34, should contain P alarms, high and low.
The bed storage and transfer hoppers should contain level indicators, for there is no way to tell the storage capacity of the hopper without looking through the fill port.
" Justify this lack of instrumentation in the control room and explain why such instrumentation has been excluded from the VR system control room."
RESPONSE
a.
Waste Recirculation Pump - These two pumps, OVR0lPA and OVR0lPB, are designed for full-flow operation.
There is no requirement for monitoring the flow rate.
- However, pump discharge pressure is indicated.
b.
Contaminated Oil Pump - Measurement of flow rate is not required for system operation.
However, the pump speed can be adjusted via a manual speed controller to maintain the dry waste processor heat release rate a design value.
. Service Air to Fluid Bed Dryer - The service air consisting c.
of atomizing air and purge air to the dryer nozzle is measured and indicated locally via OFIVR 126 and OFIVR 131.
The operating personnel will monitor these flow indicators.
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Flush WateriRecovery Tank Pump
-.This pump is designed for. full flow; operation.
There is no: requirement'for monitoring the. flow rate._- However, the discharge pressure of the' pump isiindicated, e..: Booster' Blower - This. blower is run at a constant speed.
s-The quantity of air ' discharged tar the; blower - is controlled lar the system logic via. valve OVR 255.
This valve ~cannot be fully closed.due'to a mechanical stoplon'the operator; therefore,'the. blower cannot be deadheaded unintentionally.-
- As the air entering the Tnt system.is measured, a flow 4"
indicator-on the. exhaust is not. required.
f.-
Filter-OVRO 8F -- This F-4 filter is equipped with a AP indicator..The operating personnel will monitor the AP
-to ensure the filter has not. plugged.
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Bed Storage and Transfer Hoppers-(OVR06T and OVR07T) 1These hoppers do.not contain level indicators.
- However, the fluid' bed dryer vessel ~OVR0lD and the. dry waste pro-cessor vessel OVR03S are equipped with-level-indicators.
This provides an indication of the volume of bed material that is to be transferred from OVR01D to-OVR07T or from OVR03S to OVR06T.
Furthermore, hoppers have a capacity-
'50% greater than the OVR0lD and OVR03S operating bed volume.
This precludes overfilling hoppers when transferring bed material.
Also, the bed material is weighed prior to initial loading into the OVR06T hopper to preclude overfilling.
There is no need for level indication on the hoppers.
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! QUESTION 321'.99' "There.appearsEto be a significant difference in the instrumentation on.the VR system described in AECC-2-P(NP) and-the system installed at Byron /Braidwood.
It appears 2
that a substantial amount of instrumentation has-been deleted _at. Byron /Braidwood.
Please provide a justification for each~of these omissions."
RESPONSE
The' instrumentation on the VR system installed at Byron is essentially identical to that'de' scribed in Topical Report No. AECC-2-P(NP).'_ The apparent differences are due to the manner used to show it on the P&ID's.
There are separate instrumentation diagrams for the Byron project that show the instrumentation in the same detail as the Topical Report.
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