ML20107C352
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Jersey Central Power & Light Company %4)j MADISON AVENUE AT PUNCH BOWL ROAD
- MORRISTOWN, N. J. 07900
- 201-539-6111 I
usmern w rus
((., Public Utstities Corporation _._
General srsran i
December 2, 1974 i
s, M(0 Mr. George Lear, Chief Operating Reactors Branch #3
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9 Directorate of Licensing Office of Regulation U.S. Atomic Energy Commission Washington, DC 20545
Dear Mr. Lear:
SUBJEr-OYSTER CPiC" ""'; LEAR GENERATING STATION DOCKET NO 50-219 GASEOUS RADI0AC".VE WASTE SYSTEM MGoffICATION Your letters dated 0-taocr ". 1974 nd Octo'ver 30, l'/74 requested that
==="ranea eli=* = can ~ ca=aadata faic condi ti~" =4 *h *arract we provida to the construction and operation of tne Oyrter Creel gaseous radioactive vaste system modification as described in our June 1,1973 submittal. On this basis you indicated that the pr oposed modifd.4.1vo, are acceptable.
With' ths. axeytion se the second provision, which we have altered to reficct the utilization of the unrege ;,can energy per disintegration in the T huit of the off gas radioact ivity release rate at the end of the delay line, we have complied with yain provisions.
.his is shown in the attached responses to your concerns.
The alteration of the second provision has not compromised the intent of your concern, but has merely modified the listing of the operating restriction in a manner which is more suitable for use as a Technical' Specification limit.
Very truay yours, Wnn. nlh' 6'< AP l
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i Ivan R. Tinfrock, Jr.
Vice President asb S
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12215
-r 9604170323 960213
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QUESTION 1.
We find the proposed modifications for a non-seismic gaseous radioactive waste system is acceptable provided that you will commit to designing the systems to Quality Group D (augmented) as described in the enclosed Sections IV and V of " Design Guidance for Radioactive Waste Management Systems Installed in Light-Water-Gooled Nuclear Power Reactor Plants".,
t dated August 28, 1974.
RESPONSE
The Augmented Off gas system will be designed'to Quality Group D (aug-mented) as described in the referenced attachments. These attachments are l
reproduced on the following two pages.
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e 11.3.1 November 27, 1974
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DESIGN GUIDANCE FOR RADIOACTIVE MANAGEMENT SYSTEMS I
INSTALLED IN LIC1fr-WATER-COOLED NUCLEAR POWER' REACTOR PLANTS l
DIRECTORATE OF LICENSING 1
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- IV. Definition of " Quality Group D-(Augmented)"
In addition to the requirements inherent in the codes and standards
' listed in Regulatory Guide 1.26 for Quality Group D, the following j
criteria, as minimum,' should be implemented for components and systems designated as " Quality Group D (Augmented)" in this guide, t
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The Quality Assurance provisions' described in V of this guide
_should be applied.
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b.
Pressure retaining components of process systems should utilize joints or suitable rapid disconnect fittings should be used j
welded *7nstruction to the maximum practicable extent.
Flanged only where. maintenance or operational requirements clearly indicate that such construcci>n is p.eferable.
Screwed' con-1 I
nections in which threads provide the only seal should not be used except for instrumentation connections where welded con-nections atu uot suitable.
Faucesc lines should not'be less than 3/4.irmh.
Screwed u,. uectinne backed un by seal.velding,
. socket welding or macht.-tual ioints may 've used on lines greater than 3/4 inch but less than 7.1/2 inch nominal si=e.
For lines l
of 2-1/2 inch nomin:1 piec size an? above,. pipe we1Js should be 4
of the butt-joi it : >pe.
backing rings should not be used in.
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---de-r --her particulste matcr' '
'll cidint constituting the pressure bouncary Of pressure retaining com-l ponents should be performed by qualified welding procedures in accordance with ASME Presa.c2 and Vessel (' ode >.ection IX.
c.
Completed proces, systets should be pressure tested to the maximum i
i practicable extent. Pipir.w systems should be hydrostatically
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teuted in their entirety ut.lizing temporary plugs at atmospheric tank connections. Testing of piping systema should be performed in accordance with ANSI B31.1, ASME in-6111.1 and NB-6111.2, but in no case less than 75 psig.
The test p: essure should be held for a minimum of 30 minutes with no leakage indicated.
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l-V.
Quality Assurance for Radioactive Waste Management Systems A program shall be established char is sufficient.to assure that the design, construction,,and testing reoairements are met.
The following l
areas shc21d be included in the program d
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Design and Procurement Document Control - Measures should be U
established to insure that the requirements of this design guide F
are specified and included in design and procurement documents and that deviations therefrom are controlled.
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b.
. Control of Purchased Material, Equipment and Services - Measures should be' established to assure that purchased material, equipment and construction services 1 conform to the procurement documents.
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Inspection - A program for inspection of activities affecting quality should be established and executed by, or for, the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for.
accomplishing the activity.
d.
-Handling, Storage and Shipping - Measures should be established to control the handling, storage, shipping, cleaning and preser-vation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
e.
Inspection, Test and Operating Status - Measures should be established to provide for the identification of items which have satisfactorily passed required inspections and tests.
f.
Corrective Action - Measures should be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected, i-i 4
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QUESTION
- 2. -
We-find the proposed modifications for a non-seismic gaseous radio-active waste system is acceptable provided that the off gas radio-activity release rate from the steam jet air ejector will be limited to not greater than 260,000pCi/sec (af ter a 30 minute delay).
f RESP 0NSE The Oyster Creek Technical Specifications presently state that:
"The maximum release rate of gross activity, except fodines and particulates with half lives longer than eight days, shall be limited in accordance with the following equation:
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.21 Ci/sec.
Q
=
Y where Q is the stack release rate (Ci/sec) of gross activity and E is the average ramma energy per disintegration (Mev/ dis)."
The valus 260,000 : Ci/see was chos - #or' the 'avalysis of augmented off gas system influent activity rate because it mepresents the value Q most fre-quently derived from weekly Ef calculations. This value was assumed to be a constant influenhto tne'off gas treatment system, resulting in much higher loading on.nc charcoal beas than will be the case during actual operation.
.3,uu.ption in conj unct+ an v4......e isvge h;.o p time
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associated with the Augmented Offgas System results in calculated off-site doses less than those allowed in tie proposed Appendix I.
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As indicated in Semi-annual Reports #10 (1/1/74 - 6/30/74) and #6 j
(1/1/ /. - 6/'a//2) spikes in the release rate Q do occur when the mechanical J
S vacuum pump is energized during startup after a shutdown of one to two days duration.
The spikes v.y be of 5 to 10 minutes duration, but data has shown E under such conditions to be typically 0.09 Mev/ dis, nuch lower than the 1
average value of about 0.8 Hev/d'e. and yielding an allowable Q value of 2.32 Ci/sec. This is within acceptable off-site dose limits in accordance with the Technical Specification noted above but is, of course, greater than the 260,000 pCi/sec limit required in your letter of October 1, 1974.
4 In view of the occurrence of these release rate spikes with very low E values, and in view of the importance of E in the dose considerations, it is requested.that the oft-gas radioace.1vity release rate Technical Specifi-cations limit from the ctaam jet air eje.ctor:should be as follows once the aug er.ted gas system becomes operational:
"The maximum influent rate of gross activity to the augmented off gas system (as determined at the end of the delay pipe), except iodines and particulates. with half-lives larger than eight days, shall be limited in accordance with the following equation:
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. Q =.21 Ci/sec E.
where Q = release rate in Ci/sec determined for the end-of the delay pipe, and
- F average gamma energy in Mev/ disintegration.
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i QUESTION 3.
We find the proposed modifications for a non-seismic gaseous radio-active waste system is acceptable provided that you provide assurance >
that the off gas system can be reliably isolated within 10 minutes of a failure in the system.
RESPONSE
Noncondensible gases are removed from the three main condensers through six 10 inch air ejector lines.
Each line has an isolation valve which is auto-matica11y closed by explosion detectors in the offgas system.
The explosion detectors are two temperature and two pressure switches located in the off-gas holdup pipe near the steam jet air ejector.
i' Automatic isolation of the three main condensers will only occur under the
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~following conditions:
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Detection of high temperature by both the high temperature cwitches or 2.
Detection ~ of Sigh pressure by both the high prer, ora ceicches or s.
3.
,natection by one high temperature and by one high pressure u
switch.
Detection of high temperature or high pressure by any one switch wil'1 annunciate in the control room but will not isolate t, main condensers.
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In addition to the automatic isolation of the three main uondensers. the isola-
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tion valves may also be closed from remote manual switches trom the main co.t:rol
.rocn or from a local valve control switch.
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'Bes. ides isolation at the main condenser, isolation capability exists for each of
- he redundant augmented offgas (AOG) system trains.
'The A0G system to be installed at the end of the existing delay line will consist of the following equipment:
1.
Recombiner subsystem consisting of the following redundant components :
preheater, blower, catalytic recombiner and recombiner cooler.
2.
Water Kemoval Subsystem consisting of redundant ecodenst rs, chillers and freeze-out heat exchangers.
3.
Charcoal Tanks.
4.
HEPA Filter.
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4 An isolation valve is located upstream of each redundant recombiner subsystem and an A0G system bypass valve is located in the base of the stack at the end of the existing delay line.
These valves are semiautomatic, air operated.
The isolation valves automatically close and the bypass valve automatically opens to isolate the ADG System under the following circumstances:
1.
Low flow in air recirculation line around the recombiner cooler unit.
2.
High temperature in the exit stream from the recombiner.
3.
High'hy'drogen level in the exit stream from the recombiner.
The isolation valves are designed to fail closed if either air or electrical operating power are lost.
In addition to the above mentioned automatic isolation features, provision will be made in the main control room for the following annunciations, con-trols and indications:
e 1.
Annunciation of high radiation level ia t.0C building area.
2.
Annunciation of high radiation level in AOG building ventilation exhaust.
3.
Annunciation of A0G system trouble via one annunciator point.
4.
Ability to manually isolate the A0G system via nc pushbuttdn.
5.
Annunciator indicating both A0G isolation valves are closed.
6.
Low offgas flow annunciator.
The control room operator, by procedure, will be required :to -loolate the j
system within 10 minutes of receipt of either high builditig ares.radia' tion ~ -
annunciation or high building ventilation exhaust radiation annunciation.'
These high radiation annunciators are indicative of an A0G System component failure.
" System Trouble" annunciation indicates that one of the above mentioned abnormal conditions exists and the system requires attention.
The "Iow Offgas Flow" annunciator on the A0G Panel in the main control room is provided to indicate the occurrence of a break in the delay line or a break in the 4" line carrying the Offgas to the A0G System.
The " Low Offgas Flow" annunciator will annunciate only if the flow measured ec the inlet of the Recombiner Subsystem in the A0G building is much less than-the flow an-i i
ticipated at the minimum operating power level.
Upon receipt of such an annunciation the operator, by procedure, will isolate the three main conden-sers within 10 minutes using remote manual switches located in the main control room.
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QUESTION 4..
the find th'e proposed modifications for a non-seismic gaseous radio-active waste system is acceptable provided that you provide assurance
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-that the delay time for noble gases. passing through the delay pipe j
j is not less than 60 minutes.
RESPONSE
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The' design of the off-gas delay pipe is based on providing a 30 minute delay of the gases to provide time for short-lived isotopes to decay before
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release.
This assumes normal in-leakage to the main condensers. - If the leakage. to the main condensers can be reduced the off-gas flow rate will be reduced and the holdup time increased. This reduces the radioactivity dis-charged to the atmosphere and therefore, the doses due to normal operations.
Continuous efforts at Oyster Creek to reduce condenser in-leakage have i
resulted in nominal delay times of 60 sinutek, thus reducing gaseous radio-l active dischorges. Ucacver assurances can not be given that a 60 minute holdup time can be maintained in a syctem designed for 30 minutes. However,.
the augmented off-gas system provides greatly ^$ncreased delay of noble gases before they cre disenarged and thet.n orc undct noraal ooerating vanditions J
the delay in the pipe will not *.
a4 gr i f.icant.
i The analysis of a ruptur' in ti e delay pipo sheur-thatcthe concents of the delay pipe and the genes whien entes ir before isolation of the steam-jet air eje
.?..::.. i".. atino sphere.+ <he long...~..
dt.~ay time, the greater is the noble gas inventory which is available for release.
Isolation'of the air ejectors is accomplisbad within 10 minutes of the rupture of the delay pipe system so ct.at the dose attritatable to the noble gas inventory availsble in the pipe is greater than that attributable to
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the gases that tiow into tne pipe 2fter the break. Therefore, it can be
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4 seen that reducing delay time rede:at the noble.gne. inventory available for release taua therefore the doses resulting from the release of that inventory).
A 60 minute delay assumption in this accident analysis conservatively covers the most probable situation, i.e., delay time 1-:a than or equal to 60 minutes.
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