ML20214E604
| ML20214E604 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1587, NUDOCS 8705220164 | |
| Download: ML20214E604 (114) | |
Text
FCPSE /577 OIGINII4 n
UNITED STATES Lj NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON NUCLEAR PLANT CHEMISTRY LOCATION:
WASHINGTON, D.
C.
PAGES:
1 - 83 TUESDAY, MAY 19, 1987 DATE:
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AG&5Uff$(([iPY lad 0llM9Vdom ACRS0" ice ACE-FEDERAL REPORTERS, INC.
! Reporters 444 Capitol Street Washington, D.C. 20001 8
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PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS A
TUESDAY, MAY 19, 1987 4
The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the-meeting held on the above date.
No member of the ACRS Staff and no participant at n
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this meeting accepts any responsibility-for errors or inaccuracies of statement or data. contained in this transcript.
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l' UNITED STATES OF' AMERICA ~
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NUCLEAR ~ REGULATORY COMMISSION
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ON' REACTOR SAFEGUARDS
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SUBCOMMITTEE ON NUCLEAR PLANT CHEMISTRY 4:
5 Nuclear Regulatory: Commission
.t Room 1046 6-1717 H Street, N.W.
Washington, D.
C.-
7' Tuesday,'May 19,;1987' 9
The: subcommittee meeting convened at 1:00 p.m.,
' 10' Dr.--Dade W..Moeller, chairman, presiding.
11 ACRS~MF.MBERS PRESENT:
12
[
' DR. DADE W.
MOELLER
- 13 DR. J. CARSON MARK 14 MR.. JESSE C. EBERSOLE 15 16 ACRS CONSULTANTS:
17 MR. FIRST
'.18 MR. ORTH 19 20 21 22 23 O.
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P R O C E'E D I~N G S
'2 DR.'MOELLER:. (presiding).
The meeting willTcome 3
ta) order.
4 This is. a meeting of the ACRS Subcommittee cn1 5
Nuclear-Plant Chemistry. - I am Dade Moeller.
6 The oth'er ACRS members in attendance are Carson
~
7-Mark and Jesse Ebersole. -Then we.have two consultants with' 8
us,;Melvin First and Donald Orth.-
9-The purpose of ~ this meeting is ta) be briefed and 10
^ discuss the. revised-sections of the standard review plans 11
. published within NUREG 0800:
12
" Standard Review Plan for the
(
13~
review of safety analysis reports 14 for nuclear power plants, the LWR 15 addition."
16 Revision 2, Section 6.5.2.and Section 6.5.5.
~17 Herman Alderman, seated on my right, is the 18 cognizant ACRS member present-for today's meeting.
~19 The rules for participation'have been published 20 as part of the notice of this meeting in the Federal 21 Register on May 13, 1987.
22 It is requested that each person taking part 23 first identify himself or herselt and speak with sufficient 1
- 24 clarity and volume so that he or she can be readily heard.
)-
25 We have received no requests for time to make I
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. oral statements by members of the public.
If any member of j
2 the-public, though, desires to contribute to the meeting, 3
simply let us know and we will try to provide time to.you.
l 4
As I understand it -- and our speaker, I am sure, j
5 will clarify this -- the main objective of this afternoon's 6
meeting is to go over these two proposed revisions to the 7
standard review plan.
We have previously commented on them, I
8 and-of course one of the things to do is to see how much 9
they took our comments into account.
10 But I believe the objective is simply to concur 11 with them, if we do, that these should be published for i.
.12 public comment.
If that is not correct, I am sure they will 13 correct me.
}
- 14 DR. MARK:
When did we make our-comments?
15 DR. MOELLER:
It has been roughly a year ago.
16 MR. ALDERMAN:
October 15th, 1986.
17 DR. MOELLER:
At that time, Dr. First, who is 18 here as one of our consultants, kindly read and commented in 19 writing on one of the revisions, and Dr. Ronald Bellamy, who 20 is also an expert on nuclear air cleaning, read and 21 commented on it, and then I offered some comments.
22 Okay, with those remarks then -- well, are there 23 any other comments?
24 MR. EBERSOLE:
Dade, I skimmed through this, and
()
25 I called your attention to two years ago, well before GESSAR
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II, it was well-known that the suppression pool could be 2
called upon for a decontamination factor to permit the 3
direct release of steam of f of a cleaned,' undamaged core to -
4 atmosphere if one were forced to the wall and had to recheck 5
feed from the containment and retain fission product in a 6
damaged condition.
7 I think overy effort, whether formally or 8
informally, everyone knows -- in the back of his mind knows 9
damn well you had better have access to open venting through 10 the suppression pool of a core that is undamaged by direct 11 boiling at near atmospheric pressure through a suppression 12 pool which is at 212 plus K degrees in the summertime, the
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13 whole object being to release a very small amount of 14 radioactivity to prevent catastrophic later core melt.
15 Containment, after all, has two products.
It is 16 supposed to keep radionuclides inside, but it has got to get 17 the heat out.
18 If it fails to get the heat out, if you don't 19 cool the suppression pool early on -- and that is of course 20 one of the causes for core melt -- you can avert it very 21 easily by simply letting the pool boil and letting the 22 vessel boil through its decompression system and pass the 23 steam through the air space and run it down through, whether 24 you condense or do not condense, and then discharge it n(,)
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of discharge which the reactors might well have.
2 The system in GESSAR II was called the UPPS, 3
ultimate plant protection system.
It brought enormous 4
improvement and major relief.
5 I don't see anything in here about this more 6
practical use of the suppression pool rather than' mitigation 7
after the core is shut.
Critical to that is balance of 8
plant, where you find a release which is permissible to 9
prevent a larger release, a balance which NRC has never 10 struck yet.
11 I think it would be pertinent to have something 12 in here about that plant.
t'
(_j) 13 DR. MOELLER:
I agree with you that there is a 14 need to address that question which, as you have pointed out 15 many times, is very fundamental, where you purposefully 16 release a small amount of fission products in order to avoid 17 a major release at a subsequent time.
That would be during 18 the progression on accidents or what you suspect or fear.
19 I think they have heard the comment.
So we will 20 ask them if it is appropriate.
21 MR. EBERSOLE:
It is the first place I have seen 22 a good place to put something like that.
23 DR. MOELLER:
I gather, Jerry, that you will be 24 addressing, then, the PWR containment sprays first and the
(~)
(j 25 BWR suppression pool second.
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Let's lead off then.
Either sit at the table if v
2 you prefer.
We all have your handouts.
So there is really 3
no need to project it.
4 MR. HULMAN:
Let me just use the handouts and go 5
over them with you.
Let me make two comments before I 6
start.
7 First, with respect to getting your concurrence 8
to issue these two changes to standard review plans for 9
public comment, we have already issued then for public 10 comment based upon our presentation and your comments last 11 October.
12 DR. MOELLER:
Okay.
Then I stand corrected.
()
13 So what is our purpose today?
14 MR. HULMAN:
The purpose is to comment on the 15 version that was issued for public comment, and we would 16 appreciate any comments on suggestions you would care to 17 offer in that regard.
18 DR. MOELLER:
We were all provided copies.
We 19 have read it, and it is simply my misinterpretation of where 20 we stood.
21 MR. HULMAN:
I apologize for not informing you of 22 that earlier.
23 With regard to your comment, Jesse, I think you 24 make a very good point, and I think the staff would probably
()
25 agree that more work with respect to emergency procedures ACE-FEDERAL REPORTERS, INC.
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and with respect to possibly licensing guidance for use of 2
suppression pools as a preventive device for core melt needs 3
to be done.
4 But I don't think that these two standard review 5
plans are the place for that.
6 MR. EBERSOLE:
I am just taking whatever platform 7
I can find.
8 MR. HULMAN:
I am making the suggestion to you 9
that as part of the subcommittee's comments maybe they might 10 like to offer that as a comment, that staff seek a place to 11 appropriately describe, and it may very well be done in any 12 case because the staff is reviewing Revision 4 to the
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13 emergency planning guides for boiling water reactors, and 14 that might be the appropriate place.
15 And if the comment were addressed not simply to 16 the Office of Research but to NRR, who is doing that review 17 at this moment, it might be appropriate.
18 MR. EBERSOLE:
You can imagine the consternation 19 with plant management if he sees an oncoming core melt 20 merely because his containment is getting hot.
21 MR. HULMAN:
He should be using the suppression 22 pool.
23 DR. MOELLER:
Okay, that is a good suggestion, 24 and we will be writing a letter.
So maybe we will put a
()
25 paragraph in there.
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Let the record show that Mr. Soffer and Mr. Read 2
are here, also, representing the NRC staff.
3 MR. HULMAN:
Let me move forward and say that we 4
are here to discuss the two standard review plans that Dr.
5 Moeller has identified and were issued for public comment.
6 I have with me Lynn Soffer, who is the section 7
leader in the Severe Accident Issues Branch in the office of 8
Research.
He is going to discuss the rationale for the 9
changes to the two standard review plans.
10 Jacques Road, who is a senior reactor systems 11 engineer within the same branch, is going to discuss the 12 technical bases for the changes.
(~%
is,)
13 I am going to give you some of the background and 14 also discuss the regulatory implications.
15 On the third page, I have given you a very brief 16 history of how the staff has evolved guidance with respect 17 to design basis accidents and the fission drives associated 18 with them.
19 In 1962, Part 100 and its reference to TID 14-844 20 wac issued.
I will remind you that in that particular 21 regulation there was reference to substantial core melt.
22 There was recognition, in my opinion, of accidents well 23 beyond the design basis and the need to consider them in 24 both siting with respect to Part 100 and with respect to O)
(_
25 engineered safety features in terms of plant design.
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In 1972, the staff attempted to codify its review 2
procedures in the first issuance of the standard review 3
plan.
In that particular standard review plan it was the 4
first time the staff put down on a piece of paper what bases 5
they used to review various issues associated with 6
construction permits associated with operating licenses.
7 It has been revised twice since then.
8 In 1985, the fall of 1985, I came before ACRS 9
with a plan to implement what was understood then to be 10 source term research and severe accident research with 11 respect to specific items in regulatory practice.
We 12 identified ten of them for you.
They are included on the
(~
(_)j 13 next viewgraph.
14 We received your comments, which I thought were 15 very encouraging at the time.
16 In 1986, Zoltan Rosztoczy, who was then 17 responsible for the subject matter af ter the reorganization 18 of November 1985, presented to you SECY Paper 86-76, which 19 formalized the plan for implementing source term changes.
20 My understanding is that the Commission has in 21 essence endorsed the staff effort.
They haven't endorsed 22 any changes, but they have endorsed the staff looking at 23 these areas of research implementation.
24 Earlier this year we issued the revisions to the w
25 standard review plans that we are here today to discuss for ACE FEDERAL REPORTERS, INC.
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public comment.
This is the first implementation result of 2
the source term research with respect to integrating it into 3
licensing practice.
4
.The last item on my history list is current 5
status.
Virtually all reactors in the United States today-6 have been under construction and are expected to have 7
received operating licenses this year.
As a result, the 8
bulk of the-staff effort associated with the subject of the 9
source term would be for accident management and for 10 reviewing license amendments.
11 Staff continues to get an inordinate number-of 12 requests for licensing amendment changes from utilities.
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13 They are either sharpening their pencils or they find 14 something wrong or they find a design error.
But there are 15 a large number of requests for licensing amendment.
16 The staff is still busy trying to reduce that 17 backlog.
My recollection is that the backlog runs to 18 something over 3000 license amendment requests per year.
19 I have identified on the next slide those 20 potential source term change areas.
Today we only want to 21 talk about the two standard review plan changes, but if you 22 are of a mind to discuss any of the others, we can give you 23 the status on those as well.
24 Now, with respect to standard review plan 6.5.2,
()
25 I would like to turn to Lynn Soffer and ask him to go over ACE-FEDERAL REPORTERS, INC.
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some of the rationale for some of the changes.
i 3
v 2
MR. SOFFER:
Good afternoon.
I am Lynn Sof fer, 3
one of the section leaders of ACRS,~in the Issues Branch in 4
Research.
5 In looking at this viewgraph, looking at the 6
place of standard review plan 6.5.2 in the scheme of things.
7 It is one of the standard review plans that is invoked by 8
the DVA local dose calculation.
9 The containment spray function is a dual purpose.
10 It is used as a containment removal system, and it is also 11 used as a fission product cleanup system.
In this 12 particular revision, we are only looking at its fission f3'q) 13 product cleanup status.
14 As you can see, there are a number of SRPs in 15 Section 6 that are concerned with fission product cleanup 16 system sprays, other fission product control systems and 17 structures which typically deal with dual containments and 18 ice condensors, and as we will talk later, we are proposing 19 the addition of a new one in Section 6.5; namely, 20 suppression pools.
21 You can see that these are in turn feeding into 22 Chapter 15 of the SRP, where the radiological consequence 23 calculations are actually performed.
24 There are also several other SRPs that are
()
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'in particular, things like control room habitability, 2
hydrogen' generation for' example, equipment qualifications, 3
one or two others.
4 Going to the'next.viewgraph, the present version l
5
.of SRP 6.5.2 first of all is based primarily upon TID 14
'6
.844.
The: radioactivity is assumed to be'in containmentLat' 7
the time equal toLzero. -The composition is assumed to bei
!8 noble gases andLiodine, and the iodine is primarily 9
elemental in form, and the composition is spelled out-in the 10 SRP and it is quite specific that it is about, I believe, 95
~
11 percent elemental, et cetera.
12
~ A spray additive'is strongly encouraged.
It is
()
113 not required, but it.is strongly encouraged.
If it is i
14 present, it is. required to be injected automatically.
15 DR. MOELLER:
There generally is always a time 16
. delay, though, for that automatic injection, is there not?
17 MR. SOFFER:
.I believe as part of the acceptance 18 criteria, Dr. Moeller, there is allowed a delay of no more 19 than 90 seconds.
If the spray.comes on within 90 seconds, 20 then the staff can give credit for immediate improvement, 21 but no later than that.
f
.22 DR. MARK:
That was 907 i
23 MR. SOFFER:
That is correct.
l 24 DR. MOELLER:
As I recall, that was put in to F
()
25 prevent having caused an inadvertent actuation?
i
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MR. SOFFER:
I believe that that was the case, 2
but that was also an incentive to get applicants and 3
licenses to bring spray in fairly early, also.
4 MR. HULMAN:
But it didn't prevent inadvertent 5
actuation because we already had that.
We had that at TMI.
6 MR. SOFFER:
The present standard review plan 7
gives low iodine removal credit unless the pH in the sump is 8
greater than 8.5 and there are no explicit models for spray 9
removal coefficients or plateout deposition.
10 DR. MOELLER:
To help me, where you have a 11 containment spray system, you inject the sodium hydroxide 12 generally into this containment spray water.
/~s
(_)
13 What does that make the pH of the spray as it 14 comes down?
Is it 8.5?
15 I ask because then you have TSP, don't you, in 16 the sumps; you don't have both?
17 Can you help me?
18 MR. READ:
Jack Road.
19 The pH can vary widely.
As a matter of fact, one 20 of the requirements is that it not be permitted to go above 21 11 and the diversity is keyed -- the diversity of means of 22 mixing, some of these means are quite sophisticated.
There 23 is a positive displacement pump that is keyed into the speed 24 of the main pump.
But some of them are quite simplistic,
()
25 for example --
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MR. SOFFER:
Gravity feed systems.
2 MR. READ:
Some of them just mount in sodium 3
hydroxide solution into the containment storage tank.
4 DR. MOELLER:
Then do you have trisodium 5
phosphate in the sump as well as injection of sodium 6
hydroxide into the spray?
7 MR. READ:
No, sir, there are a few plants.
9 DR. MOELLER:
Without any sodium hydroxide.
10 So once they start recirculating, their pH is up?
11 MR. SOFFER:
That is co' erect.
12 DR. MOELLER:
How long intc an accident or into
()
13 the spraying cycle do you begin to recirculate?
Is it 15 14 minutes, or do you know?
15 MR. READ:
Betwoon 20 and 45 usually, 16 DR. MOELLER:
Thank you.
17 MR. SOFFER:
Going on to the next viewgraph, this 18 viewgraph will give you just an overview of the proposed 19 revision of SRP 6.5.2.
20 As part of the background, as Mr. Hulman has 21 discussed, it is one of the short term changes discussed in 22 SECY 86-76.
There are three major points that are proposed 23 to be changed.
24 One is that the revision removes the emphasis on
(( )
25 the immediato injection of spray additives.
It retains ACE. FEDERAL REPORTERS, INC.
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post-accident sump pH control but at a' lower pH level.
As 2
we have seen, that is 7, and we will discuss-the bases or 3
provide the bases for that.
And it extends the evaluation 4
of the spray to other fission products in addition to 5
6 So it recognizes the fact that sprays can be 7
effective in the removal of other fission products besides 8
iodine and proposes models to evaluate that.
9 There are several other aspects that are 10 important.
It does not depend upon a particular source derm 11 inside containment.
We have deleted the reference to TID 12 14-344.
(_j) 13 The proposal at this point, as you will see later 14 on, is intended to be used either with TID 14-844 or with an 15 intended revision to Reg Guide 13-14, which is yet to come.
16 There is no licensee action that is required; that is, the f
17 action is voluntary.-
18 In summary, this represents a relaxation with no 19 nignificant detriment to safety, but we believe a cost f
20 savings to the industry and an operational benefit as well 5
l l
21 because of the prevention of inadvertent actuation.
22 The revisions on the next viewgraph are a little 23 bit more detailed.
It will delete the requirements for l
l 24 spray additive during injection and for automatic addition.
()
25 It bases the sump pH control on the need to keep iodine l
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revolatilization at a very low level.
2 It removes the TID source term, replacing it to 3
reference Reg Guides 13 and 14.
It provides explicit models 4
for isotopes other than iodine, provides explicit models for 5
natural depletion processes, and will permit a variety of 6
spray systems to be reviewed; for example, BWR sprays, which 7
right now the staff does not review on a regular ba' sis as 8
well.
9 It also deletes procedures for reviewing 10 ineffective additives, such as sodium thiosulphate, which is 11 no longer being used.
12 MR. EBERSOLE :
Did you say that the staff does (3
v) 13 not review the BWn r. pray systems at all?
14 MR. SOFFER:
Not as fission product removers.
15 MR. EBERSOLE:
That is the qualifier I wanted to 16 hear.
17 MR. SOFFER:
Not as fission product removers.
18 MR. EBERSOLE:
That is all, and it has another 19 critical function?
20 MR. SOFFER:
Yes.
21 Let me now turn it over to Jacques Road, who will 22 talk about some of the technical bases for the proposed 23 changes.
24 MR. READ:
As Lynn said, the principle new source
()
25 term -- the reason for this changes is to have in place a ACE FEDERAL REPORTERS, INC.
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standard review plan that would permit review of some other 2
source' term assumptions and those in TID 14-844.
3 In addition, of course, these are fairly old 4
plans, and there are a variety of problems that have cropped 5
up with them over the years.
These are more things to be 6
borne in mind in considering the changes rather than the 7
bases for them or the motives for them.
8 A substantial number of experiments have been 9
done with the sprays.
10 In particular, there is a series of Japanese 11 papers and one Italian paper from the University of Pisa 12 which came right out and said that as far as they could see
(
13 there was no real pil intended for the original spray, and 14 the Japanese pointed out that indeed if you were to follow 15 the model that appears in the NUREG CR-0009 you could in 16 fact for most of the reasonable region of the parameters in 17 the equation cross out the effective pil and cancel.
18 The Italians did it empirically.
They took a 1 19 percent solution of sodium thiosulphate, which should have 20 been extremely offective, and prepared it in spray with the 21 local tap water and found it not significantly dif ferent.
22 If indeed you look at our containment sprays and 23 back out just those initial spray periods, you confirm those 24 results.
()
25 MR. FIRST:
Your statement there should be ACE FEDERAL REPORTERS, INC.
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amended, shouldn't it, saying hence, additives not needed 2
during initial spray injection?
3 MR. RETD:
I am sorry.
By injection you mean the 4
way in which it is used in the standard review plan?
5 It means when you are drawing down from the 6
reactor refueling water storage tank.
e 7
MR. FIRST:
So the rest-is recirculation?
8 MR. SOFFER:
Injection carries with it the idea 9
of initial.
10 MR. FIRST:
Thank you.
11 MR. READ:.The operative thought being that there 12 is no predissolved iodine.
()
13 MR. FIRST:
No, I understood.
14 MR. READ:
There have also been problems in pH 15 control considerations as to whether or not the pH would get 16-considerably higher, and if you look at what ought to be the t
17 ideal pII you find that at about the pH of 9 or so there are 18 reasons to believe that that is too high a pH.
You are 19 interfering chemically with the natural bent of the 20 atmospheric oxygen in the containment.
21 To continue to oxidize iodine up to the 10 state, 22 which is its stable form on the planet Earth, in connection 23 with the activity above a pil of 9 or so is safety 24 detrimental.
()
25 Thoro is no evidenco stating that a p11 of between ACE. FEDERAL REponTEns, INC.
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7 and 9 that there is any reason to choose within that 2
range, nor is it likely that you would be ab'le to set it 3
exactly experimentally during the real accide'nt precisely, 4
except within a renge.
5 Now, there were two additives that were mentioned 6
in the original standard review plan; namely, the sodium 7
thiosulphate and hydrazine, which we have deleted.
Both of 8
these have problems.
9 Thiosulphate was used only once and then was 10 removed.
The problem is that thiosulphate is eaten by 11 bacteria, has to be stored in a sterile state.
It 12 decomposes to form a variety of other sulfur oxides and (O
13 sulfur itself, and sulfur even in small amounts can cause
_j 14 embrittlement of nickel alloys.
15 Sulfur of course has boon blamed for the 16 embrittlement of the nickel alloys in the steam generator 17 tubos that are occasionally used in sulfide cleaning.
18 Eydrazine is an excellent way to react with 19 iodine.
Unfortunately, it is a magnificent way to react 20 with oxygen as well.
It hydrolyzes with a very high G 21 value, and there is overy reason to believe that if indeed 22 there were a TID 14-844 source term dispersed into a PWR 23 containment, any hydrazino appearing at the top of the spray 3
24 would bo oxidized before a drop gets to the sump.
O(_)
25 In a real accident or an accident as viewed by ACE FEDERAL REPORTERS, INC.
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on site would be expended prior to the release of any iodine 3
in virtually all modeled accidents.
-4 Again, the next slido just goes on to mention the 5
Italians and the Japanaso and our reexamination of our 6
experiment.
7 The next slide has a lot of chemistry in it to 8
indicate that there is indeed a large complex series of 9
, things that can happen to iodine once it gets inside the 10 containment.'
11 There is an extremely fast hydrolysis reaction.
12 If a lot of iodino were to be released as a vapor, it would rx
(_)
13 very, very rapidly react with water to form iodine and 14 strange intermediate FO lotis acid, which may or may not 15 exist.
It may be something else.
16 A very slow reaction, although it is not that 17 slow in the presence of heat, and so on.
But it could very 4
18 easily be of the order of several hours.
Well, eventually 19 air will oxidize the iodino.
With most of the iodine on the 20 plant, that is the form it takes.
21 In addition, there ace some exciting things that 22 lodino catalyzos in decomposition in peroxide, and peroxido 23 is made in fairly copious amounts by reactors with ionizing 24 radiation on the water.
O)
(,
25 What this means is that water is around ahd you ace. FEDERAL REPORTERS, INC.
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are irradiating it and the iodine will be involved.- There v
2 will be a continual generation of elemental iodine and a 3
continual destruction of it.
And so there will be a dynamic 4
equilibrium.
The iodine will continually change its form.
5 In addition, iodine has a place in the earth's 6
atmosphere and it is destroying methane.
And so iodine will 7
need help in the oxidation of methane.
It will also 8
catalyze hydrogen.
9 If there is elemental iodine around, this is an-10 excellent way of letting hydrogen down because there is no 11 activation energy involved.
12 The next slide shows the tenth of a microsecond G
()
13 values that describe the radiolysis of water.
You can see 14-the comparatively copious amounts of hydrogen peroxide that 15 are made.
You can also see that the 2.7 should have an OH t
16 or a minus on top of it.
17 But be that as it may, you can see that there is 18 more hydrogen ions made and hydroxyl ion.
In the presence 19 of a radiation field water will tend to be somewhat acidic, 20 and if you can put in something to scavenge some of the 21 other things, it will go markedly acidic.
22 Very recently, an experiment was done at Oak
'23 Ridge in which water continually saturated with nitrogen was 24 irradiated and was driven to a markedly low pH of about 10
()
25 to the 8th rad.
t ACE FEDERAL REPORTERS, INC.
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This of course was brought out by the ATS study 2
group.
Gus Allen suggested that nitric acid could indeed be 3
made in the containment atmosphere and that nitric acid had 4
been made in some Canadian plants where nitrogen is used in 5
the pressurizer.
6 Nitric acid is not made in PWRs, even though 7
there is nitrogen in the pressurizer, simply because of the 8
presence of hydrogen.
So the presence of a comparatively 9
small amount of hydrogen will koop down the generation of 10 nitric acid.
Nitric acid is extremely important here 11 because of course it can oxidize iodine very nicely.
12 In the regulatory analysis that was released for gm_)
13 public comment along with the standard review plan, there is s
14 a description of some radiolysis of iodina solution 15 experiments which indicate that if the pH is below 4 you can 16 make very copious amounts of elemental iodine by irradiating 17 aqueous solution and if the pH is above 9 the formation of 18 lodate will be partially prevented.
19 That ends what I have to say.
20 MR. HULMAN:
Any questions on the technical 21 bases?
22 DR. MARK:
Could you remind me in what sort of a 23 scale they stand as to biological hazard?
24 MR. READ:
The various iodines.
(-)s 25 DR. MARK:
The elemental is at the top of the y
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g 2
MR. READ:
I believe so.
I had a conversation 3
with Pete Eckerman at Oak Ridge about this, because-it was 4
my feeling that~obviously organic iodide, methyl iodide l
~
5
'would be comparatively insoluble and therefore it should 6
have a lower biological ef fect.
But his opinion was that 7
this was not a very large effect.
It was not orders of 8
magnitude, as I have suspected.
9 The other form, of course, is as particulate, and 10 there if it is in a soluble form or insoluble form it makes 11
_all the difference.
1 12 Of course, some of the models indicate that r'
i )T 13 silver ' iodide might be extremely soluble.
But if_it is s
~
14 cesium iodide --
15 MR. HULMAN:
It depends on the compound, not just 16 the isotope, the compounds that are formed within the 17 containment and outside the containment.
18 DR. MARK:
I was thinking only of the compounds.
19 The cesium iodide is bad because it is so 20 soluble.
The insoluble ones are biologically less damaging.
21 MR. READ:
We are discussing Part 100 here, which 22 only worries about whole body and thyroid.
Obviously,-
23 there's a tradeoff.
If you inhale something and it is 24 insoluble, you get lung dose.
If it soluble, you get O
ta reid dose.
2s v
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It.is your decision as to which dose you'want.
~
2 MR. HULMAN:
Wa intend to fully explore the 3
relationship between the various~ compounds that could be.
4
. released an'd the dose calculations.
We intend.'to bring that 5'
-back to you within the next year.
6 DR.. MARK:
I have the feeling!that I-should know 7
it, and I know:that I don't.
8.
MR. HULMAN:
I have the same feeling'.
I should-
~
9-
'know it as.well.
10-I.am sorry, but I don't.
11-I want some of. our ' contractors to go through' that.
F 12 fast.
13.
DR.~ MARK:
Thank you.
4 14 15 16 17-18 19 20-21 22 23 24
~
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MR. HULMAN:
On the next slide, we talk about the 2
proposed implementation for SRP 6.52.
It requires no change 3
for present PWRs.
That is, it is voluntary.
Licensees have 4
the choice of maintaining the status quo with what they've 5
got.
They also have the choice of using automatic addition 6
of spray additive, manual addition, for example, on high 7
radiation signal, not necessarily on containment isolation 8
or the use of no additives, but somehow they've got to 9
assure pH control.
10 The additional benefit from the way in which SRP 11 6.52 has been recast is that it is independent of the source 12 term assumptions.
It will allow the Staff to revise, for
(]
13 example, Reg Guides 13 and 14 without direct reference to 14 TID.
It is a set up for future action.
15 Just to give you a feeling of what is out there 16 in the industry --
17 DR. MOELLER:
Excuse me a second.
I haven't read 18 Reg Guides 13 and 14 for sometime.
Do they not reference 19 TID 14 824?
20 MR. HULMAN:
They do not directly reference them; 21 however, they are based upon them, with some additions and 22 potential errors in the translation from TID to Reg Guide.
23 The next Vugraph shows what is out there in 24 industry.
I think it is important to understand that not
(~;
()
25 everybody is using spray additives for that initial spray.
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In the proposed changes to Reg Guide 652 is a plant by plant 2
list of what is out there for additives.
This is simply a 3
summary.
There are 53 plants using sodium hydroxide, and 4
there are seven PWR units using TSP for pH control.
It 5
turns out that all seven are CE plants.
That doesn;t mean 6
that every CE plant has them, but seven of them do.
Most 7
importantly, with respect to regulatory impact is that we 8
-don't perceive any of these changes that we have proposed to 9
change public risk at all.
10 It is basically a regulatory improvement 11 implementing what we have learned about source terms or 12 experimental evidence.
What we have learned about severe
!,s,)
13 accidents.
14 DR. MOELLER:
Excuse me.
What do the French and 15 the Germans do?
16 As I recall, it seems I have heard the Germans do 17 not use anythng.
18 MR. SOFFER:
I don't have complete information on 19 that.
As far as I am aware, I'believe the French use 20 additives; I believe the Germans do not.
21 MR. HULMAN:
I am not sure that all of the German 22~
plants are without.
I think some of them have additives.
23 DR. MOELLER:
The French, if they use it, it is 24 probably sodium hydroxide.
-()
25 MR. SOFFER:
I believe that it is sodium ACE-FEDERAL REPORTERS, INC.
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.1 hydroxide.
I remember discussing this with a representative 2
from Switzerland, who was very glad that we.were instituting 3
this-change, because he said their plants did not have any 4
a'dd'itivesd.
5 DR. MOELLER: -That is helpful.
6 MR. HULMAN:
Let me go through the other. impacts.
7 I'want to try and expand on some of the statements that are 8
in here.
As I said, there is no perceived change in publ'ic 9
- risk.
There.is -the potential for reducing personnel 10 hazards in maintenance and operation.- For example, there is 11 at least one-incident that has been reported at the Staff, 12 where there was an-occupational hazard created during the (f
13 maintenance operation, when sodium hydroxide was spilled.
14 At least one worker was -- I think it was burned -- and 15 quite clearly the shoes on the bottom of his feet'were 16 almost burned away.
That particular utility wants very much 17 to get rid of sodium hydroxide.
They find it a hazard.
18 They find it a maintenance headache, and by the way, if' 19 somebody happened to be in containment, and there were an 20 inadvertent actuation, it could be fatal.
21 MR. EBERSOLE:
That occurred at Sequoyah too, 22 except that it was an additive.
23 MR. HULMAN:
If it occurred with additives, it 24 could be a problem.
(_)s 25 MR. EBERSOLE :
There were people -- I think it 14CE FEDERAL REPORTERS, lNC.
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was ten.
2 MR. HULMAN:
It could be bad.
What is it, sodium 3
thiosulfate that was at TMI.
There was nobody in 4
containment, when they had that inadavertent actuation, as I 5
remember, but there have been inadvertent actuations.
They 6
are a threat to personnel.
They are also a threat to 7
equipment.
So doing away with the additive has the 8
potential of reducing both of those hazards.
9 DR. MOELLER:
And it was sodium thiosulfate.
10 Maybe this is what you said in TMI Unit 1 that ruined the 11 steam generator, 12 MR. SOFFER:
Quite correct.
13 MR. EBERSOLE:
As a matter of fact, if you make a 14 mistake, if you have the raw materials, it could generate 15
_ hydrogen.
16 MR. HULMAN:
It could generate hydrogen, 17 unnecessarily.
18 DR. MOELLER:
So when you say no perceived change 19 in public risk, at the same time you are pointing out that 20 occupationally or in-house, it could have many benefits, 21 like money.
22 MR. HULMAN:
That is correct.
It is a better way 23 to put it than I did.
We think the changes that would 24 implement the standard review plan by individual utilities
(~)s 25 would result in relatively small hardware changes.
As a s_
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matter of fact, we are not. talking about changing any 2
equipment.
We'are just talking about talking out the 3
additives, completely out of the system, flushing them, 4-cleaning them and letting the water run through them, but 5
.for those that-would take out sodium hydroxide, for example, 6
we would require pH control, in the way of TSP.
For 7
example, in stainless steel baskets, and so forth.
8 The Staff resources required to review license 9
amendments, always appears large to the Staff, but in this 10 particular case, I don't think it is significant.
I think, 11 if a group of owners were to get together and come up with a 12 generic kind of license amendment and get-it reviewed p)
(_
13 generically,-the Staff resources would be miniscule.
.If 14 they wanted'to do it on a case by case basis, I think they 15 would still be small.
16 That, in essence, is the summary of what we 17 propose to do, why we propose to do it and what the impacts 18 are likely to be with respect to spray additives for PWRs.
19 Are there any questions we can try and respond 20 to?
21 DR. MOELLER:
Okay.
We had asked this one 22 earlier, and it is getting a little ahead, but what is the 23 pH of the water in a BWR suppression pool?
24 MR. READ:
It is quite clear that it should be
()
25 very close to 7.
It will always be slightly below that, ACE-FEDERAL REPORTERS, INC.
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because of the dissolution of carbon dioxide from the 2-atmosphere.
There is always some air around, but certainly, 3
6.8 to 7.
4 MR. EBERSOLE:
Have they put any additives in 5
there, in order to prevent rusting of those carbon steel 6
vessels?
At one time, there was going to be some chemical 7
put in there like your automobile to prevent of the carbon 8
steel, but I think they have abandoned that and gone to 9
painting.
10 MR. READ:
The two common anoxidants are 11 marcolone and hydrazine itself.
There is dimethylhydrazine 12 and a couple other hydrazine derivatives that are sometimes 7,
i) 13 used.
But in their application they would be like an x
14 automobile radiator.
If you try to get it, you have to keep 15 on adding until you got all the oxygen that is left behind.
16 MR. EBERSOLE:
So it is not nice to pour that 17 stuff in the core.
18 MR. HULMAN:
My understanding is, th,ey have been 19 painting.
20 MR. EBERSOLE; That has been my understanding and 21 that's been very troublesome.
22 DR. MOELLER:
Under this new approach, you will 23 allow or give credit for the spray, obviously, as an iodine 24 renoval mechanism or feature.
n
(_)
25 MR. HULMAN:
Yes.
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DR. MOELLER:
Now to maintain the pH at 7, a new 2
-lower number, you will still' need the TSP -- I mean the 3
operators) 4 MR. HULMAN:. You could keep the same additives 5
you've got now,.as long as that additive weas sufficient to 6
maintain the pH at 7 or better han 7, it woulf be all right, 7
or you could take out the Na OH and put in the TSP.
8 DR. MOELLER:
On page 6.5.2-3, if you have it 9
with you.
10 MR. HULMAN:
We are getting it.
What is the page i
11 again?
12 DR. MOELLER: '
3.
6.5.2-3.
You know, your lines k,_m.
)
13 on the right'are where you have made changes.
Take 14 paragraph A, system operation.
I had a problem, and I am 15 sure you can explain it.
The first sentence says."The 16 containment spray system should be designed to be initiated 17 automatically."
Then the last sentence says, " Additives to-18 the spray solution may be initiated manually or 19 automatically."
20 I thought we had been saying we would not do it 21 automatically.
22 MR. READ:
The spray has to be.
23 DR. MOELLER:
Oh, the spray would be automatic.
24 MR. HULMAN:
The additive can be a choice.
(f 25 DR. MOELLER:
Do you consider then the TSP to be ACE-FEDERAL REPORTERS, INC.
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-an additive?
2 MR. READ:
Yes,: sir.
3' DR. MOELLER: -So-when you say additive-to the
~4 spray; solution, okay, maybe initiated manually or 5
automatically.
6 MR. SOFFER:
Or maybe stored in the containment 7
sump pipe.
8 DR. MOELLER: ~ So you are still allowing them to
'9 operate'in the mode in which they choose.
~10 MR. SOFFER:
Yes.
l'1 D:R. MOELLER:
But you are giving them 12 suggestions.
All right.
That is clear now.'
It.is a case
(
13-of reading it carefully.
o
,14 Now at pH *l, will the iodine evolve from the 15 water?
16 MR. READ:
No, sir.
17 DR. MOELLER:
I saw your curve, and it looked 18 likeLit came down.
19 MR. READ:. Obviously, some of it will come out, 20 but there'is a minimum amount.
21 MR. FIRST:
Isn't it dependent upon the maximum 22 amountlof iodine that you are going to pick up for a'given 23' quantity of spray water and also the temperature?
l 24 MR. READ:
If you were exactly pH 7, you could
()
25 control it there.
That would depend on the extent to which i-ACE FEDERAL REPORTERS, INC.
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you were able to get organics into the solution by 2
radiolyzing; paint or getting it out of an automatic oiler or 3
.something, the metal. iodide.
4 MR. FIRST:
But you are assuming now that the 5
reactions of the elemental iodine are going to be so fast 6
that'you don't set up any kind of equilibrium between the 7
dissolved iodine and the concentration in the atmosphere; is 8-that correct?
9 MR. READ:
Well, the hydrolysis reaction is fast.
10 There will be an equilibrium eventually.
It is_just that it
^
11' will be very much in; favor of the developed forms.
12 MR. FIRST:
What would be the concentration of
()
13 iodine onto'the most absorptive regime of any of the plants?
14 Do you have something on that?
15 MR. READ:
It could no greater than 10 to'the 16 minus 4 moles per liter.
17 MR. FIRST:
Because of the volume of water you 18 are talking-about, but they don't all have the same volume 19 of water, do they?- They all have the same potential for 20 releasing iodine?
21 MR. READ:
I don't know about potential.
22 Obviously, iodine has a very high specific activity, 23 meaning, of course, that most of the iodine that is made is 24 radioactive 129.
There is very little 127 stabile iodine
()
'25 that is made.
So iodine is one of those materials that ACE-FEDERAL REPORTERS, INC.
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burns in slowly.
2 We always assume that it is am end-of-lifetime 3
core, in which case, it would be about 100 moles of iodine, 4
principally 127 and 129, that would be available.
And the 5
extreme that you could have in a very severe accident, of 6
course, you could be struck with just the 300 tons of 7
primary coolant water, and everything failed.
8 MR. FIRST:
This is my point.
When you made that 9
calculation, you still come out with something like 10 to 10 the minus 4.
11 MR. READ:
That would be the most we could get, 12 if, indeed, the feedwater storage tank came, undoubtedly, it-t'(,) -
13 would be much less than that, since there would always be 14 something that would be tied up inside the primary vessel, 15 and in addition, of course, there would be other sinks. Thew 16 paint would glom some, and then the silver would precipitate 17 some, as it did'at 3 Mile Island.
18 MR. FIRST:
But you are not taking credit for 19 that.
20 MR. READ:
No.
21 MR. FIRST:
Just what you get in the water 22 itself.
23 MR. READ:
Yes.
I 24 DR. MOELLER:
You may have answered this.
Will rm is,)
25 Reg Guide 1.4 be revised?
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MR. HULMAN:
Our intention is to consider a y_t 2
change.
We have a contract under way now with Brookhaven, 3
in which Brookhaven is assisting us assessing the results of
~
4 the use of the source term code package to see whether it is 5
feasible to come out with a simplified revision of TID 6
14844.- The results to date appear promising.
7 DR. MOELLER:
This is a technical aspect that I 8
need to understand.
If you use TSP to adjust pH, do you
-9 then -- I am just talking about the utility.
Do they simply 10 store in the sump the proper amount of TSP, so.that it ends 11 up at about a pH 7?
In other words, it-is the total 12 quantity.
I guess -- well, does the TSP dissolve
( )/
13 immediately or each time it washes over it, it sort of 14 dissolves some more?
15 MR. READ:
It would be fairly rapid.
We wrote it 16 down.
It has been used in dishwasher detergents, and it 17-will cake, and so it may take some finite time for hot water 18 to dissolve it, if not boric acid, but it would be quite 19 rapid.
20 DR. MOELLER:
What'is it in?
Is it already 21 dissolved into the water in the sump, or is the sump dry to 22 start with?
23 MR. READ:
The sump, hopefully, is dry.
24 DR. MOELLER:
It is in a basket, a wire dish?
()
25 MR. READ:
Yes, above it, it is stainless steel 1.
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foil,:with many holes punched in it, at least the one I saw.
2 DR. MOELLER:
And then when spray sprays and 3
fills the sump, it swishes around and dissolves it?
4 MR. READ:
Yes.
5 MR.-HULMAN:
Like a dishwasher.
6 DR. MOELLER:
On page A-20, that is this
~
7 Brookhaven report, on page 20, and this again is just for my 8
education.
There is part 5, discussion and conclusion.
9 There.is a long paragraph that begins about a third of the.
10 way down and one of the last few sentences in that 11 paragraph.
The last sentence, I guess, it says, one is the
.12 effectiveness of fresh spray' solution, and the other.is that
)
)
13 since the CSS is activated on high containment pressure,
.14 that is my first question.
Is that the only basis 1that you 15 actuate?
You don't use temperature.
I guess containment 16 isolation can be initiated by two or three dif ferent 17
, parameters.
But then you are saying the containment spray l'8 only actuates on high containment pressure.
19 MR. READ:
High, high, high.
I think.
20 DR. MOELLER:
That is reasonable.
Now it says 21 that since it is activated by high containment pressure, it 22 is quite possible that the CSS will have switched from the 23 injection to the recirculating phase, prior to the release 24 of any fission product activity.
I take it, they are saying
()
25 in the containment.
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So what you are saying, and I presume TMI 2
followed this too, you can have, even if you have a' break, i
3 the initial steam or water that is escaping into containment i
4 is relatively free of fission products until such time as 5
you get to the point of really severely damaging the core.
6 MR. HULMAN:
It is the PWR analogy to-Jesse's BWR 7
problem.
8 DR. MOELLER:
You are releasing heat.
9 MR. HULMAN:
You are releasing heat, you are 10 blowing down, and you haven't yet affected the core.
11 DR. MOELLER:
So that is quite possible that 12 there would be no fission product release until you are in
,c\\
\\_)
13 15, 45 minutes, 20, 45, whatever it is.
14-MR. HULMAN:
Other than that, that is dissolved 15 in the coolant.
16 MR. EBERSOLE:
A very top popular topic is 17 primary blowdown, a far simpler cooling process than trying 18 to reject heat from the secondary, on that Glenn Paed is 19 trying to promote every time he opens his mouth, I think.
20 That would be a precore damage effort, as well.
21 DR. MOELLER:
Any other questions on this?
22 MR. FIRST:
I have on on page 652-13, the top of 23 the page there.
I frankly couldn't understand what was 24 meant.
It says, the last sentence there, "Because the f^)x
(_
25 removal mechanisms are significantly different and slower ACE FEDERAL REPORTERS, INC.
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1 L for -organic iodides and' particulate iodines, therefis no
.. ~.
7 2
need to limit the.DF allowed ' in the -analysis fo'r these 3
iodine forms."
Do I interpret that to mean.that you can j
ll-calculate a DF max greater than 2001or organic' iodine or.
5
-particulate lodide, so that you don't even consider them in
~
4 6
- this context?
I am'asking for understaning of what that; L
7 means.
a 8
'MR. READ:
- Okay, In application, we would use a i
9.
computer code made up of differential equation, and there.is.
10 a coefficient that depletes.each form of iodine that would--
j:
11 be in the containment.
That is the PACT code:-- P-A-C-T.
12 At present, when it is used,' the ~ maximum DF is n
3_),
13
-installed as a'stop time, at which time the computer-is told.
14 to disregard the' sprays further.
Now'that sentence means-15-simply;that you do not turn off the effect of the sprays I~
16
.concerning the organics and the particulate.. If you read
. 17 elsewhere,'you will see that unless the-applicant makes a 18 case otherwise, we will assume that the sprays.are totally =
19 ineffective against organic iodide, and 'I forget exactly 20 what it is, but after some fraction of the particulates have 21 been removed, the efficacy of the sprays against 22 particulates are reduced by an order of magnitude.
So it-is 23 true, according to our models, the removal of those two 24 types of iodine will be quite slow, and there would be no
( )f 25 real purpose served towards Part 100 by stopping them.
i
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MR. HULMAN:
It is a conservative calculation.
2 MR. FIRST:
What I don't understand is whether 3
you would add whatever effect you were able to calculate, as 4
far as organic iodides to the 200 that you have specified on 5
the preceding paragraph.
6 It says that the maximum DF will be 200.
What I 7
don't understand is whether you then add to the 200 DF 8
whatever you might have calculated by this other program, so 9
-that you come out with a greater than 200 DF by some 10 mechanism.
11 MR. READ:
The DF refers only to that particular 12 form of iodine.
I appreciate this that you are aware, if g.
(_)
13 you like, there will be a rapid dynamic equilibrium, perhaps 14 even an intense equilibrium among the several forms of 15 iodine than at present, but the coded present doesn't know 16 that.
TID doesn't have it in it, and even the source term 17 code package, of course, doesn' t.
)
18 So as that is written, we will start off with the 19 various forms of iodine and do each separately, so the 20 element iodine will be stopped by dilution, by a factor of 21 2.
22 The )ther two forms woud not.
So it would be 23 more like subtracting the DF 200.
24 MR. FIRST:
How would you subtract, if you are (q
25 calculating what these other mechanisms are going to take j_
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out, in addition to your max of'200?
1!-
LMR. HULMAN:'
It' would be more like.-- he didn't
- 3 say he would subtract.
It is al separate calculation for 4
each iodine form.
5 MR. FIRST: ' Fine.
So'we can end up with a DF of 6
more than 200, you are saying.
- 7 MR. READ
In theory, yes.
8 MR. HULMAN:
My understanding is, you'can wind up.
.9
-with more than 200 for those other forms.
10 MR..FIRST:
I.mean altogether, not.200 for 11
_ organic.
12 MR. HULMAN:
Altogether, yes.
()-
~
13 MR..FIRST:.
In other words, there isn't an 14 absolute ceiling of 200.
15 MR. HULMAN:
Right.
16 MR. FIRST:
How does this' interact then?
If you 17 take credit.for-200 with your sprays for elemental-iodine 18 and some of it reevolves to your equilibria, are you now-19 going to take credit for removing them by the other-20 mechanismm in addition to the 200 which you may then have 21 lost?
I mean, I don't understand how that interacts.
22 MR. READ:
The original purpose of stopping the 23 DF, original 200, was to permit half a percent of iodine to 24 always stay there, regardless.
The sprays, obviously, would
()
25 have taken it out.
So it was, indeed, a method of modeling ACE FEDERAL REPORTERS, INC.
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- _.s.
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- reevolution, if you will, making that'DF of 200 says.that as 2
far-as the elemental-iodine is concerned, you will always 3,
have half a percent floating around.
That is the net 4~
effect.
5 MR. FIRST:
Then you are saying there is an 6
absolute limit, a DF of 200, because that is the half 7
percent.
8 MR.-READ:
Of the elemental iodine.
9 MR. ' FIRST:
I am talking about the.other forms.
-10 MR. READ:
The other forms could go to zero.
11 MR. HULMAN:
The DF is continued.
It is not 12 limited to 200.
It is just the elemental.
()
13 MR. FIRST:
Fine, but my point is,'after you'have 14 taken your 200, and if you have reevolved some of that, 15 aren't you counting it twice?
16 MR. HULMAN:-
You are not counting.it twice.
It 17 is being washed into the sub and reevolved.
I don't see how 18 you are counting it twice.
19 MR. FIRST:
But then you may be taking credit for i
20 it in other forms.
21 MR. HULMAN:
I see.
Yes, that is possible.
s 22 MR. FIRST:
I realize that we are talking about a 23 half percent.
We are not talking about an awful lot, but 24 nevertheless --
()
25 MR. HULMAN:
It was a computational artifact i
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designed to assure that you always had elemental iodine
[
2 available for leakage from the containment.
3 MR. FIRST:
I see.
Well, anyway, it does seem to t
4' me that there is a little uncertainty there. _ Whether it is 5
realistically important or whether it is just a quibble, I-6 am not' sure._
If I had to make the calculation now in regard 7
to the take out of particulate material, you also have a 8
limit on that, and you made the statement a little while 9
ago, that after a certain time, the sprays are not very 10 effective, because presumably that the particle size has 11 changed Lapidly.
12 In the comments that I made earlier, I ask'ed the
-( )
13 question why you used a two-step model.
In other words, 14 your first calculated on the basis of the original particle 15 size and size distribution.
And all of a sudden at.some 16 point in the calculation, you went to an altogether 17 different mode of size with no intervening transition, and I 18 asked the question, is this a good way to do it, or should 19 we, since we can calculate what the change-in size and 20 concentration will be with time, since our model should be 21 able to do that sort of thing, in order to be a reasonably 22 good model, why we just didn't just run it out, as you would 23 with a constant change in size and concentration.
24 MR. SOFFER:
It was basically a desire to keep it
()
25 a relatively simple model.
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MR. FIRST:
I can understand that,.but.could you 2
tell me, or do:you have some information on what the 3
magnitude of the change would be, if you did it by the two 4
methods, one I suggested and the-one you do use, which I 5
agree has the advantage of simplicity, how different;would 6
the answers be?
That is my question.
7 MR. SOFFER:
I don't think that we have evaluated 8
it.
9 MR. READ:
As far as the amounts are concerned, 10 they were referred to in the original standard review plan, 11 but they didn't appear in it.
So what I did was was to just-1-
12 take the models as they appeared in the references, which (ss) 13 are mostly NUREG CR 0009, and just put the equations in.
14 And I believe the two step comes from there, and I believe 15 they do have a variety of graphs, of which the two steps fit 16 what God does.
17 MR. FIRST:
I saw that, and, frankly, I was not 18 terribly taken by them.
19 MR. HULMAN:
If you vill be certain that that 20 comments gets in the ACRS letter, we will make certain that 21 in response to comments, we will address it explicitly, and 22 if, in that process of addressing it, it is worthy of 23 changing the stuff in the standard review plan, we will do i
24 that, but we will address it explicitly first.
()
25 Dr. Moeller gave me the impression he had ACE FEDERAL REPORTERS, INC.
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' transmitted.my comments-to you.
That is why I am bringing 2
~it out.
3 DR. MOELLER:
Yes.
Your comments were, though, 4
primarily, on the BWR; suppression pool.
5 MR. ~ FIRST:
I thought.that was one I did have.
6 DR. MOELLER:
I think so, but-you see, it was in 7
the letter on the BWR, not in this.PWR,
~8 MR. FIRST:
Would it make any difference?'
9 DR. MOELLER:
Probably so.
10 MR. HULMAN:
We will look at it.
11 DR. MOELLER:
Tell me what the statement should el 2 be, roughly.
()
13 MR. FIRST:
I don't know, Dade..I didn't bring 14 the copy of the letter.
I thought you were referring-to it.
15 So I am at a little disadvantage at the moment, but-I can 16 return it.
17 DR. MOELLER:
We will be-taking a break, and we la have your letter.
19 I have a question.
Is_the standard review plan a 20 regulation?
21 MR. HULMAN:
No.
22 DR. MOELLER:
Then, on the same page, 13, down at 23 V,
Part A, you say " Operating plants and OL applicants 24 pending at the date of issue of this revision, need not
()
25 comply with the provisions of this revision," which is sort ace FEDERAL REPORTERS, INC.
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of a regulatory wording.
2 MR. HULMAN:
You are right.
It is "need not 3
follow the guidance," and I think that is a worthwhile 4
comment for regulatory language.
5 DR. MOELLER:
Any other questions or comments?
6 MR. HULMAN:
I do note that licensees must 7
address NUREG 0800, but need not comply with it.
It is not 8
a regulation.
9 DR. MOELLER:
Okay.
Any other comments or 10 questions?
11 (No response.)
12 DR. MOELLER:
There being none, let me ask then (m,)
13 what the Staff would like from us, from the committee,
/
14 specifically?
15 MR. HULMAN:
Since I am the smoker, I would like 16 a break!
17 (Laughter.)
18 DR. MOELLER:
We will be taking a break, as soon 19 as you tell us.
20 MR. HULMAN:
We would like comments from you that 21 reflect any suggestions for additional considerations or 22 changes and whether you agree with the thrust of the changes 23 we proposed.
24 Do you think what we proposed is a good idea or
()
25 not, is basically what we are after, and if you think it is ACE-FEDERAL REPORTERS, INC.
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I a good idea, how do you'think we might improve it?
4 i
2-DR. MOELLER:
That is clear.
And Herman,'you've 3
got that.
i 4
'I think with that, we can certainly conclude the
^
5 formal presentation here.
I am going to keep discussing 6
bri.efly with the. committee or the subcommittee to get our 7
comments down.
Then we will take an official break and 8
resume.in 25-minutes.or so for the BWR part.
9 Why don't we have a discontinuation of the
~
1 10 recording and jus.t take a break.
11 (Recess.)
12 i ;
13 l
14
.15 16 1
17 18
+-
19 l
20 i
21 22 i
23 r
24
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DR.'MOELLER:
The meeting will resume.
I think, v
2 in terms of the part we've just completed, we certainly will 3
write a letter that favorably looks upon the proposed 4
revisions.
We certainly concur with you in terms of what 5
you're doing.
6 We'll move on then to the second item, which is 7
the suppression pool as fission product cleanup systems.
8 We'll go through that and again ask what it 's you need from 9
us, and try to respond.-
10 MR. HULMAN:
Okay.
Let me say that Len Soffer 11 will give you the status and an overview, ' and Jacques Read' 12 will continue with the technical bases all lined up with the
( })
13 regulatory impact, just like we did on the previous one.
14 Len.
15 MR. SOFFER:
Thank you, Jerry.
16 On your next viewgraph, the one you should all be f
17 on is the one that's labeled suppression pools as fission 18 product cleanup systems - present status.
19 As you can see from the bullets, according to Reg 20 Guide 1.3 at the present time, no credit for suppression 21 pools is given as a fission product cleanup system.
22 Nevertheless, there is some discussion in SRP 23 6.5.3 that states that pool credit may be given, but it 24 provides no procedures or criteria for the staff to.do so.
()
25 So, immediately, there is sort of a conf 1'ict.
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addition, there are several othe'r complicating aspects.
SRP v
2 6.5.1, criterion 5, permits charcoal filtration-if it's to 3
be non-PSF grade, if lesg than 90 percent efficiency is
-U claimed.
'e l
5 Finally, in.the GESSAR 2 review, the staff did, 6
allow full credit in the severe accident risk part of the
.7 evaluation.
,l
'l s 8..
DF, MARK:
It did' allow full credit.
Were there
'h 9
laid-down procedures for developing the amount of credit 10
'that could be claimed?
11 dlR. SOFFER:
No.
There was no standard re' view A
12 procedure to my knowledge, there was merely a discussion of
,n
(
)
13 the fact th&t, in the event of severe accidents, it was'r v
14
,likely that suppression pools would be --
.1
'l MR. HULMAN:
For. severe Mccidents.
But also for
/15-v 16 design basis accidents.
We took the position that credit 17 could be claimed, but it was'n't really necessary in the case
,i i
18 of GESSAR to detonstrate c,ompatability with Part 100.
=19 We did acknowledge for the first time'in that 20 review that you could take credit in the design basis 21 accident, but we didn't say how.
22 DR. MARK:
And you didn't say what limit you 23 would consider.
24 MR. REED:
The big problem here was GESSAR made a
()
25 big point of, stating what was in and what was not within the ACE FEDERAL REPORTERS, INC.
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'l scope'of their application.
And the bypass ~from the drywell 2
into the containment around the suppression pool was in the
'3
- balanceLof plant.
ll' So they were not going.to specify that.
That I 5
think was the largest single motive for not dealing with an 6
event there.
We had to combine releases via both 8
pathways in order to get the Part 100 dose estimate.
9 y DR. MARK:
Okay.
Anyway, it's proposed that this 10-will be'made a little more clear and specific.
11 MR.' SOFFER: 'That's correct.
12 MR..EBERSOLE:
GESSAR was also the vehicle by
()
13 which G.E.' proposed to do this direct boiling.
But they did 14 it in such'a. sloppy way, it was really just'a crude 15 conceptual outline.
They had a few simple, specific 16 features to enable it.
17 MR. SOFFER:
Do you mean'the UPS. system?
18 M P.. EBERSOLE:
Yes.
And along with it, there was e
' 19 no work done.
There was just a lot of loose language and
. 20 arm-waving.
But there was a good deal of subsequent 21 discussion about the fact that there would be virtually 22 invisible radionuclides on the outside through invoking this 23 mode of cooling.
24 But it's unfinished.
Incomplete.
["s')
From the staff's point of view, I r
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can't comment'on your view of what G.E. did other than to
%J 2
'say that we didn't review emergency procedures'and we didn't 3
review the amount of pool scrubbing credit that we would 4
propose to give under design basis accident conditions.
5 We did conclude that some credit was in order.
6 And we also put a. mortgage on that credit for future 7
applications.
And this is fulfillment of that mortgage.
8 MR. SOFFER:
Let me go on to the next viewgraph.
9 This again is basically a repeat of the_one-that you've seen
~
10 earlier on the standard review plans that are invoked by.the 11 DVA LOCA dose calculation.
12 This' time you see that we are proposing to add a
(
13 new section which would be labeled pressure suppression t
14 pools.
That's the only real point that I. wanted to make 15 with this one.
Let's go on to the next viewgraph.
16 This one contains an overview of the proposed new 17 SRP.
Again, this was one of the short-term changes that was 18
' discussed in SECY-86-76; the implementation of the source 19 term changes the major aspects associated with this SRP 20 revision are three.
21 It would permit credit for suppression pools as l
22 fission product cleanup systems.
We would incorporate 23 conservative decontamination factors, DP values in the SRP.
~~
24 That would be allowed with no applicant analysis, as there
()
25 would be some conservative DP values.
And we will discuss ACE FEDERAL REPORTERS, INC.
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' those :lhter.-
3 2
Anyfsuppression pool bypass leakage:must be x3'
' accounted for'in dose calculations.
And there mustLbeLa 4'
tech spec.in the suppression pool.to maintain.those.
5
.And~the third major point is,-in keeping with'the 6
comments:made by.the ACRS subcommittee'and11ts consultants, 7
-asTwellc as'a' number of staff members, existing ESF-8
. filtration' systems are not to beLdegraded b'elow theLminimum.
9
.value.
That is, 90 percent. efficiency.
-That(is maintained 10 in Revision 2 of Reg Guide 152.
'll-
'The other aspects are similar to SRP.652.
It is
.not dependent on any particular source term in' sight.
'12 13 Therefore,'it can be used with either TID 14-844 or.any
~
14-
. potential : revision'.
And again no licensee action is 15 required.
16 And the summary is'we~believe that it represents, I
117
.a' relaxation with'no significant-detriment.to safety.
I 18' As far as the bases, let me turn it over to.
19 Jacques Read again to discuss.those.
20 MR. READ:
In truth, the R&D is based.upon the 21 SPARC code, which is the sonrec term code package.
It forms 22 the basis of why we are able to do this.. There is a
~
comparison of all available runs or experiments with the 23 24 most current SPARC code runs.
That is a few pages back.
, ()-
25 This is a very recent draft.
Prior to this, all
~
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0230,05-05 52 L(~'N/bc-1 of the' points had been off on to'the lefthand side of the
' %.)
2 paper.
That is, SPARC had been uniformly conservative.
s 3
However, it is extremely difficult to get an s
4' aerosol to go around a corner.or to' accelerate _or decelerate 5
it.
6.
So SPARC was having trouble delivering'an aerosol-7 into a_ pool, and-so were the experimenters.
SPARC has now 8
been changed'so that it more or less does it.
9-
'Unfortunately, it makes a much sloppier graph.
10 DR. MOELLER:'
The SPARC code has been evaluated.
11 and confirmed, and so forth.
I was asking myself, you know, 12 the degree to which it had been validated.
And I noticed s
( ))-
13 the Brookhaven Lab report seemed rather inconclusive in 14 terms of discussing the SPARC code.
15 MR. READ:
That may be true.
16 DR. MOELLER:
It 's the best - you have, is that it?
17 Or what?
13 MR. READ:
Essentially.
19 MR. SOFFER:
It's not the only code that exists.
20 There is another suppression pool evaluation code, referred
21 to as the super model, which I believe EPRI has evaluated.
22 The DF values that are calculated by the super code to my 23 knowledge have been greater than the SPARC code.
24 MR. READ:
And they've changed.
()!
25 MR. SOFFER:
It may have changed.
So I don't ACE-FEDERAL REPORTERS, INC.
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l' believe that we have available to us the super code.
J 2
MR. HULMAN:
It is important to recognize that 3
Brookhaven apparently was concerned about the wide variation 4
and experimental data and the inability of any code to truly 5
model.
6 If you take a look at the graph that is in the 7
published version with what Jack has just shown you, you see 8
substantial improvement in that modeling process.
But, just 9
the variation in the data is quite large.
10 So what I guess Brookhaven is unable to do-is say 11 we've got a good modeling process.
But what the staff are 12 saying is that, as a regulatory tool, it looks good enough
(( )
13 to us.
It may not be perfect, but it's adequate.
14 MR. READ:
1 think you'll all believe me that 15 there is a great deal of experimental work.
The British 16 have in their steam generating heavy water, have a similar 17 pressure suppression device.
The Swedes also have a similar 18 device.
And BNL of course was hired to supply data for 19 SPARC.
20 There's a great deal of evidence around.
In 21 addition, of course, the discussions of the source term code 22 package have raised the possibility that hydrogen iodide 23 could be a significant form of iodine that would be 24 encountered.
For our purposes we don't have to worry about l( )
25 that.
i
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Hydrogen iodidefis like hydrogen chloride, an
- M 2I extremely _ strong acid.
3 MR. HULMAN:
One additional comment.
'4-Last week at the so-called partners-meeting-on 5-the' source term and severe accident research, we were 4
~
6_-
informed that.both the Japanese and the Italians will do 7:
some additional experimentation on-suppression pool 8
scrubbing.-
And we would expect the results to be added 9
' confirmation that what we've got is okay.
10 DR. MARK: 'When will that perhaps appear?
11 MR. HULMAN:
We expect to begin to see results 12
.possibly early next year.
The Japanese have no trcuble with l,(
);
13 money, but the Italians are having a little bit.
14-MR. READ:
The next page is just a reproduction p
15 of-effective or time-averaged decontamination package for 16 various and sundry sequences,
~
t i
17 That was recorded in the B&L letter report.
As' 18 you can see, they tend to be fairly large numbers.
The 19 asterisk refers to inconsistencies in the reported values.
20
'Actually, we're still. troubled with an imbalance'in the i
21 source term code package.
That becomes key if you have to 22 take the difference between two large numbers.
23 A major part of the simplification that's been 24 achieved in writing standard review plan has been to use
'( ]);
25 time average ~ effective decontamination factors.
Just a ACE-FEDERAL REPORTERS, INC.
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simple factor to multiply something by.
V
~j 2
The next graph shows the time variation that 3
could occur just given one set of assumptions.
These are 4
taken from one of the documents quoted in NUREG 1150.
And 5
there is one of these available for any variety of 6
assumptions you might wish to make concerning how large or 7
how round the bubbles are when they come through the 8
suppression pool.
9 This one is amongst the worst as you can see.
10 The decontamination factor is late in time when the pool is 11 boiling.
And there's no longer much condensible in the 12 striving gas.
The decontamination factor goes down on the
,.-()
13 order of few to several.
14 One of the contents though, we see that the first 15 time we're here that we did not take advantage.
So the next 16 one perhaps is a figure taken from a paper which shows the 17 degree to which the use of time averaging tends to make the 18 decontamination factors much more agreeable.
19 It's being represented by a simple assumption and 20 a simple, single number.
Now there would be no real benefit 21 to any licensee or applicant by assuming an extremely large 22 decontamination factor, simply because as soon as the 23 decontamination factor becomes 10 or above, or even several 24 in most instances, the dose will be dominated by the
()
25 suppression pool bypass.
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3
.DR. MOELLER:
How does it bypass?
4-MR. READ:
There are many penetrations, 5
particularly on a Mach III.
The Mach I's are the tightest 6
of the drywells.
But, by and large', these large steam. pipes 7
are obviously hot.
They have to expand and contract.
There 8
are just many, many paths.
9 MR. HULMAN:
For example, the recent review of
'10 nine-mile point unit two, that.particular licensee had 20 11' percentnof the releases going through the bypass, compared 12 to total releases.
()
13 MR. EBERSOLE:
Would that make'necessary the E
14 invoking of' sprays to avoid bursting of the containment?
15 MR. READ:
Yes.
16 MR. EBERSOLE:
The sprays at one time were 17 nonsafety, nonengineered safety grade features.
They were 18 elements of design that were intended to improve an 19 acceptable situation.
20 MR. HULMAN:
With respect to the design basis 21 LOCA, my understanding is they didn't count on strays at 22 nine-mile.
They were not a safety feature for fission 23 product removal.
And I'm not sure they counted on them for 24 heat dissipation.
()
25 They're there in an accident.
They might work.
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They raight not.
But they were not safety-related, as 1 2
understand.
I may be wrong.
3 MR. EBERSOLE:
That's what I remember.
They were 4
manual.
5 MR. HULMAN:
But the issue I was referring to was 6
the one related to the MSIV problems at Nine-Mile.
No 7
matter how much they fixed those valves, before they decided 8
to change from ball valves back to the conventional valves,
-9 they still had the problem that over 20 percent of the 10 release was bypassing the MSIVs to begin with.
11 MR. EBERSOLE:
In that particular case, I wonder 12 if you could clarify something.
Typically, the staff n
(
)
13 invokes the hypothesis of an offsite power failure.
- And, v
14 thus, the inability to use the condenser as a cooling 15 mechanism for LOCAs.
They invoke coincidence failure of 16 offsite power, and the turbine generator on a LOCA.
17 MR. HULMAN:
Traditionally.
18 MR. EBERSOLE:
You lose the condenser.
Babcock 19 and Wilcox never do that because they can't afford to, 20 because their radionuclide discharge can sometimes come 21 through the super heater section of the tubes, above the 22 water.
And so be delivered straight to the atmosphere, even 23 for a nondamaged core, at;d result in release rates which are 24 too high to tolerate.
()
25 So they claim, and with good reason, that on an
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accident like a steam generator tube' rupture, they won't get 2.
- a. turbine trip, or they won't get a power failure.
3 I wonder if G.E. now is making any claim to be 4
'able to contain this main steam isolation valve leakage by 5
simply keeping it in.the condenser and feedwater line, which 6
would be a reasonable proposition.
7-MR. HULMAN:
G.E.
for a long time has maintained i
8 that's actually what will happen.
And the staff, in the 9
technical' resolution of generic issue C8 on MSIV LCS 10 systems, has proposed that relief be granted just that way, 11 by crediting the main steam lines in the condenser under a
~12 variety of conditions.
(f 13 If you don't have an earthquake, for example, you 14 should be able to give credit.
In fact, that is what the 15 staff.is~considering doing.
16 MR. EBERSOLE:
Doesn't that pretty much make the 17 main steamline leakage go away?
4 18 MR. HULMAN:
It makes the main steamline leakage 19 control system look like it's not only not-necessary, but 20 potentially unsafe.
21 MR. E8ERSOLE:
It does because it cheats the heat 22 sink.
23 MR. HULMAN:
It depends on whether it's a 24 positive sealing system or a negative sealing system.
If
( ))
25 you pump back into the containment, you don't have a safety l
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problem.
2 If you. don't and you let it go through the 3
standby gas treatment system, you.potentially do have a-4 problem.
5 MR. CBERSOLE:- I've often thought the energetic
-6 efforts to close the primary steam valves were not 7
particularly a good balance to strike because you lose the 8
heat sink.
9 MR. HULMAN:
You lose the steam-driven feedwater 10 pumps, that's right.
And, in fact, at least one licensee 11 has proposed under their emergency procedures not to close 12 all the main steam lines.-
( ])
13 MR. EBERSOLE:
That's what almost killed Brown's 14 Ferry when they had.the fire.
15 MR. HULMAN:
We digress.
Go ahead.
16 MR. READ:
We're all agreed that pool bypass is 17 bad and, since.it is, we should have something in the review 18' procedures that looks at it and looks at it askance.
./
19 DR. MOELLER:
Is there a regulatory limit on 20 bypass?
21 MR. READ:
Not really.
There is standard review 22 plan 6.2.3.1, which has a whole bunch of letters after it 23 for each containment.
There are 24 MR. HULMAN:
It also influences the tech specs
()
25 with respect to the type C tests.
And type C tests are ace FSDERAL REPORTERS, INC.
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limited in total leakage to the total minus the bypass.
2 MR.-READ:
Essentially, there's an indirect 3
deposit.
4 DR. MARK:
You mentioned 20 percent for Nine-Mile 5
Point.
Is that the biggest?-
6 MR. READ:
I think that-is.
7 MR. HULMAN:
I can't answer.
I don't know.
This 8
industry, I can-never tell which is the biggest because 9
tomorrow another one comes along that's even bigger.
10 DR. MARK:
Well, I'm not really interested in the 11 answer as to the biggest.
Are they all of about the same 12 order?
(
)
13 MR. HULMAN:
No.
Some of them are considerably 14 smaller than others.
15 DR. MARK:
So that's a big one.
16 MR. HULMAN:
That's a big one.
Whether it's the 17
-biggest or not, I don't know.
18 MR. READ:
I'm laying the ground that-there is no 19 advantage to having a very large DP.
There is an advantage 20 to reducing bypass.
It turns out that with those two ideas 21 in mind, there is also a substantial difference amongst 22 suppression pools that should also be considered.
I 23 That is that the amount of time that a discharge 24 bubble would spend under water passing through a suppression
'( )
25 pool is much less for a Mach I than it is for a Mach II or a i
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Mach III.
m; 2
The next page, entitled Suppression Pool 3
Diameters, shows that to be the case.
The British actually 4
only use a foot or a foot and a half or two feet of 5
submergence on their suppression pools and find that they 6
work gi. ite nicely.
7 But there is obviously a much greater confidence 8
in passing through 13 or 15 feet of water than there is 9
passing through three or four feet of water.
10 As a result, it was ag.eed collegiately to 11 propose the maximum DF values to be used whenever someor.e 12 didn't wish to run the SPARC code or an equivalent code.
I) 13 And these numbers obviously were set as low as possible.
14 without being absurd.
15 However, remember that there's no real advantage 16 to having a very large DF.
So that is not really a major 1/
consideration.
18 That's all we have to say.
19 MR. HULMAN:
Just as one aside, G.E., during the 20 review of GESSAR 2, suggested DFs in the range of 100 to 21 10,000 on the basis of their experiments.
It wouldn't make 22 much difference whether the value we gave was 10 or 100,000.
23 It's that bypass that comes into play.
24 Now, if the designer or the utility wants to I" )
25 effectively reduce that bypass, we might reconsider.
- Put, s_/
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-1 as'a practical matter, I don't_believe the utilities want'to
?s A 2
do that..If they wind up reducing the bypass, then:they 1.
_- 3
.haveLa problem with the type C tests.
4 The regulatory impact associated with the changes-5 that we are proposing to make, we've now got a little'more 6
realism in our design basis LOCA' dose: calculations.
We're 7
giving credit for a phenomenon that really exists.
We'may 8
not be giving the maximum credit, but we are giving credit.
9 There are potential relaxations that could result 10 in the performance requirements for BWR mitigated ESFs.
11-Those relaxations could come through tech spec' changes or j
12 testing requirements.
The primary candidates for changes ff) 13
.are the containment leak rate.
14 However, CRGR has suggeted that this SRP. change, 15 the one we're talking about,.not be used as a-basis for 16 changing containment leak rates at this time.
17 As part of our program, at the outset of this 18 meeting, I indicated to you that was one of the things we 19 intended to do and that's included on our third slide on the 20 package you have.
We're going to look at. containment leak l-21 rates and see whether what we've got at the moment should be I
22 relaxed or not.
And any other related containment testing y
23 requirements.
24 For example, all the air valves in BWR and PWR
'( )
25 containments typically are required to isolate in five j
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seconds. :There may be basis'in some of this new research, 2
and.I think there probably.is, for some relaxation.
With 3-
. respect to a release of fission products and failed fuel, we 4
still have the problem of releases from coolant activity.
5 Tha intend to look at that.
6
- MR. EBERSOLE:
You're touching on a very 7
interesting generic topic, on the establishment of closing 8-times for valves.
9 MR. HULMAN:
You're talking about purge valves, 10 Jessie.
I'm' talking about other' isolation valves.
Purge 11 valves, we have generally allowed 15 seconds.
Under the 12 standard review plan, it says five.
( )
13 MR. EBERSOLE:
We of course found that the valves 14 would never close at all on PWR containments because they 15 were not designed for the dynamic loadings to be imposed on 16 them in a blowdown.
17 This was a shocking finding, about 1968.
There 18 are still rumblings going on today to find that these 19 containment domes across the country in fact had no means of 20 closing.
21 I remember our own administration in Knoxville 22 saying what will our friends think when we pull this cover 23 off on them?
24 MR. HULMAN:
This was a major issue as part of fT 25 the TMI implementation.
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MR. EBERSOLE:
This was long before TMI.
v 2
MR. HULMAN:
It was probably before TMI but TMI 3.
posted limitations or the implementation fixes.
4 MR. EBERSOLE:
To get back to the valve closure 5
times, I think, in general, more often than not, you will 6
find they've been defiant not on the basis of radionuclide 7
release, but simply on the notion that one will design to a.
8 closure time that's reasonably obtainable on the grounds 9
you'll get high quality and reliability of performance in so 10 doing.
11 In other words, you impose on the vendor a demand 12 that you think if he makes it, he's going to make a good n()
13 valve.
The actual requirement in the context of release 14 rates and amounts, I think, more often than not, are by no 15 means the driving force.
16 You may find special cases where that's the case.
17 MR. HULMAN:
On the basis of a practical good 18 design.
But we're still finding utilities that are unable 19 to meet that testing requirement.
20 MR. EBERSOLE:
In those cases, I think it's fair 21 to always look at the utility and say:
Is he killing 22 himself trying to close in five seconds instead of seven 23 seconds?
When, if he closes in five seconds, the end result 24 will be that his valve will be less reliable in the context
(~')
25 of really closing that knot.
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MR. HULMAN:
Exactly.
And there may be little or J
2 no difference in the radiological consequences associated 3
with five, seven or 10 but a big difference in reliability.
4 MR. EBERSOLE:
Correct.
Exactly.
They might be 5
a hell of a lot better off to have them close against a log.
6 MR. HULMAN:
That's one of the things we want to 7
do as part of the additional follow-on work on the source 8
term.
It's a fall-out issue.
9 MR. EBERSOLE:
1 think it's a valuable thing to 10 look'into.
11 MR. HULMAN:
But there are several other areas.
12 For example, stand-by gas treatment, systems and other l( )
13 safety-related filters have testing requirements that are, 14 in some measure, dependent upon dose estimates and fission 15 product release assumptions.
16 We think there will be only a minimum number of 17 changes proposed by utilities, but it is possible 18 containment sprays, flow rates and their initiation times 19 potentially could be changed by utilities to take advantage 20 of finsion product scrubbing in the suppression pools.
21 MSIV testing and LCS testing has been a problem 22 for many utilities for a number of years.
They may decide 23 to take advantage of suppression pool scrubbing as a way to 24 reduce those test requirements.
()
25 However, offsetting this relief that we're v
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1 proposing to grant will be closer scrutiny of bypass.
We're
(_lV/bc
/
2
'giving with one hand and taking with the other.
3 Notwithstanding all of this, we don't think the' impact on 4
the staff.resourcesLto implement any changes licensee has 5
proposed will be significant.
6 Nor do we think the impact on individual 7
licensees, should they choose to implement the standard
-8 review plan, will be'large.
It's voluntary.
9 That's a summary.
10 DR. MOELLER:
Could you repeat your comments 11 quickly on item 3B, the standby gas treatment system and 12 other filters?
()
13 What did you say?
14 MR. HULMAN:
Right now, standby gas treatment 15 systems for boilers and potentially other filters that are 16 safety-related have testing requirements that are covered bv 17 the tech specs.
It's possible that by claiming credit for 18 suppression pool scrubbing, one may not delete the testing 19 requirements, but reduce their severity in terms of filter 20 efficiencies.
21 In terms of testing requirements specifically, we 22 haven't gene into that in detail.
And that's another one of 23 the promissory notes that the third slide talks about.
And 24 that is we intend to look at air filtration systems in
()
25 detail.
There is one last point to be made.
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During the break, there was some debate beween 2
Dr. First and a couple of us about whether one reduces 3
filter efficiencies to meet regulatory limits or whether one 4
does the best kind of filtration job one can.
The best 5
available technology, such as EPA is using.
6 In this particular case, we have opted for 7
meeting the old regulatory guidelines.
That is, the.10 CFR 8
Part 100 dose guidelines, if one can do that.
We've said 9
you can reduce your filter efficiencies.
10 MR. FIRST:
Let me comment that.
We also had 11 another discussion during a break with regard to the 12 reliability of the code outputs.
And the fact that we are
()
13 not considering the uncertainties in the numbers that we 14 get.
15 I would look upon the granting of credit for the 16 suppression pool as being in effect an additional safety 17 factor which helps us to overcome the uncertainties in some 18 of our model calculations.
So that we can be even more 19 certain that the not effect is going to be no worse than 20 what we have projected and are within the guidelines, within 21 the regulations.
22 So I think there's at least two ways of looking 23 at it.
The one that you proposed originally, and also this 24 aspect and, as I mentioned to you, the thing that bothers me
()
25 a tremendous amount about this whole matter of best ACE FEDERAL REPORTERS, INC.
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available technology is that the nuclear industry in general v
2 is getting such a beating from the public as it is already, 3
it seems to me we're giving them another lever on which to 4
beat us over the head.
The mere fact that we're not using 5
best available technology.
6 But, of course, they can't compare nuclear 7
procedure against EPA's procedure, for example, where they 8
have definitely adopted that.
9 I just raise the question as to whether this is a 10 good course for NRC to take.
11 12 O) 13
\\s 14 15 16 17 18 19 20 21 22 23 24
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MR. HULMAN:
I think it's more than a rhetorical
%) /bc' 2'
question.
This is what we've proposed.
If ACRS would
-3 suggest that we do something different~in that regard, I'm 4
certain that we'll consider it.
5_
However, I do make the point that some of the 6
reactors that were licensed-in the late sixties and early 7
seventies, some of them don't even have safety grade filters 8
for their control rooms, for example.
Have no filters 9
whatsoever for their control rooms.
10 If we were to as a regulatory agency impose 11 safety grade filters for some of those reactors, the cost 12
.would'not be insignificant.
!()
13 I think it's relatively easy to propose best 14 available technology, but from a regulatory perspective, I'm 15 not sura it's warranted.
16 MR. FIRST:
I think in general that you could 17 pick out situations where it might not be as you have 18~
pointed out, although I think the sense of what we talked 19 about a few weeks ago in our course was that the control 20 room people deserved and were entitled to an enormous amount 21 of protection if we wanted them to stay on the job under 22 very unsettling circumstances, and try to modulate whatever 23 is going wrong and get the reactor into a safe position.
l 24 MR. HULMAN:
No argument with that.
But, just r
().
25 how far do we go?
And are existing criteria insufficient ACE FEDERAL REPORTERS, INC.
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-and under 5109 is it justified to require backfit?
R.J 2
MR. FIRST:
Maybe the thing is just as you have 3
proposed, or just as you've stated in these proposed 4
standards, which I find to be personally very acceptable.
5 These are things that you can do if you wish.
In 6
other words, we espouse the idea that you should have higher
.7 decontamination factors rind we recognize basically that 8
there was this built-in safety factor which was tacit but 9
never spoken of; that is, everybcdy suspected that there was 10 some decontamination in the suppression pool.
11 It's certainly not a brand-new idea, but now NRC 12 recognizes it.
But, instead of saying or implying or taking
( })
13 the attitude that maybe you can now decrease some other 14 safeguard, the attitude I would like to see is:
15 Isn't this great?
We now know that we can do 16 better than we thought we were doing.
And there are other 17 areas where, if the opportunity arises, we would be 18 delighted to have you do the following; because the results i
19 would be such-and-such in terms of added safety.
20 MR. HULMAN:
But, in the particular case of the 21 filter systems, we've taken the position you can't degrade 22 below a certain level.
There's a floor below which we won't 23 allow utilities to degrade their system.
And I think that 24 basically is your point.
You may disagree with the level
()
25 we've selected, but we have established a floor.
{
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We don't think anybody should take a safety-t/
2
~ related' system and make-it a nonsafety grade, for example.
3 MR. SOFFER:
I also want to point out that we are 4
planning a reassessment of air filtration systems and 5
control habitability in light of severe accidents, and 6
source term work as well.
7 MR. EBERSOLE:
That would apply to multi-unit 8
plants as well.
Multi-unit plants.are a particular case 9
because you can have a modest containment leakage wherein 10 the source term exceeds the design source term.
11 And a unit or multiple units may be in modest 12 trouble until the operators can no longer stay.
()
13 MR. HULMAN:
There's several multi-unit stations 14 that have that problem.
There is one two-unit station, for 15 example, that shares filter systems.
16 MR. EBERSOLE:
I'm glad you pointed this out.
I 17 really didn't know we had filter systems of such low 18 quality, as you imply.
19 MR. HULMAN:
We have plants without filter 20 systems.
21 MR. EBERSOLE:
I might comment on an even more 22 serious thing, but one closely related to it.
I remember 23 distinctly about 1969 or so that we realized and 24 subsequently, when we inquired later after TMI-2, that the
()
25 input information to tie operator going in his ears, his Ace-FEDERAL REPORTERS, INC.
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~
}V/bc-1 eyes,Lwhatever he useslto get information with which to take 2'
action, was not safety grade either.
Andthereasonforthatisuptothatpoint'in 3.
4 time, '68 or
'9, the ' operator-was not an element of the 5
safety' system, per se.
It was thought, and I think this 6
came primarily from academia, that the plant would be safe 7
because-it would shut down.
In fact, life only begins after
~
8.
it shuts down, depending on what trouble it's in or not in.
9 MR. IlULMAN:
Or half-shutdown, such as at Brown's 10 Ferry.
11-MR. EBERSOLE:
So there was a brutal 12 confrontation about, my God, we have,to upgrade the
()'
13 enunciators, the indicators, ' the recorders, whatever, that
~
14 separate the wires.
Well, no, we won't.
Well, why not?
15 Because the regulations don't require it.
16 That was the beginning of the situation'that 17 exists here today -- adherence to the minimums.
So it's 18 more than just the air problem.
19 DR. MOELLER:
Okay.
A couple of comments.
20 You say in the regulatory analysis on the first 21
.page, in the first paragraph, that Reg Guide 1.3 with its 22 title states that:
23 "No credit is given for retention of iodine in 24 the suppression pool.
This is just an acknowledgment of
()-
25 what the term says."
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(~'y/bc-1 MR. HULMAN:
We've also told you that on our bi 2
plate is the possibility of revising the Reg Guides 1.3 and 3
1.4 to implement the source term.
4 DR. MOELLER:
On page 8 of that same document, 5
the first full paragraph along about the middle of it, you 6
say:
7
" Charcoal absorbers."
That's interesting.
8
" reviewed under SRP 11.3 may follow Reg Guide 1.140 rather 9
than 1.52, and are not built or maintained to ESP 10 standards."
11 Would you comment again on that?
12 MR. READ:
That's what it says.
Under the
( j 13 standard review plan, these are intended to be filter 14 systems for routine releases and not ESFs.
And for some 15 strange reason -- I do not know why -- the standard review 16 plan as quoted literally says that they are not to have very 17 high above a 90 percent iodine efficiency.
They need not be 18 maintained by Reg Guide 1.52 standards.
19 That's essentially the same as saying they're not l
20 meeting the standard.
21 MR. HULMAN:
I think it goes back to the old 22 division as to whether you need it for an accident or you 23 need it for routine releases.
l 24 If you need it for an accident, it's 1.52.
Some
()
25 systems are combined; they meet both.
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MR. FIRST:
This suggests there's another 2'
implication here.
At one time, there was a great deal of
't 3
interest inLwhat were known as guard beds,' ahead of the ESF 4
charcoal bed.
.The idea was that you could do some' painting 5
.and cleaning and you wouldn't degrade your real bed.
6 And this would not be' maintained under 1.52.
In 7
other words, they were trying to relieve the plant of 8
putting in two ESF systems, but giving them the opportunity, 9
it may well be that this exception was for that particular 10 purpose.
11 DR. MOELLER:
In any event, you might change 12 absorbers to adsorbers.
()
13 MR. FIRST:
I might add that's the same 14
~ misspelling in the proposed standard in several places.
15-Your secretary doesn't know the difference 4
16.
between ab and ad.
17
'M R. READ:
Well, it's a nuclophilic substitution I
18 reaction as far as organic iodine.
I would claim that as 19 being adsorber rather than absorber.
20 DR. MOELLER:
Okay.
This is not our 21 responsibility, but I notice in the CRGRs meeting No. 109 22 they did enumerate a number of changes or suggestions to 23-you.
24 I'm curious how many of those you adopted.
I can
()
25 show them.
We've got plenty of copies.
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MR. SOFFER:
I think in fact we did respond to 2
most of these.
We did add some sentences, for example, on 3
point number three, the CRGR, recommended that ALARA 4
considerations versus system safety requirements should be 5
balanced, and there should be a recognition of ALARA 6
concerns.
7 We have added some words on that.
On point No.
8 4, they pointed out it should be made clear that the word 9
" improvement" should be on the applicant.
If DFs above the 10 old conservative allowables were used and we could add some 11 words on that.
12 DR. MOELLER:
I think that's adequate.
I was
(>')
13 just curious.
Now, on our last letter to the EDO of
~.
14 October 15, 1986, we said on this particular SRP that, while 15 we support the proposed approach being taken for BWRs, we 16 believe that the increased dependence on suppression pools 17 does not justify the relaxation of existing requirements 18 relative to standby gas treatment systems.
19 What was your reaction to that?
20 MR. SOFFER:
Our reaction is that the minimal 21 tradeoff that we are allowing does not represent a 22 relaxation with regard to engineered safety features.
The 23 existing engineered safety features must still be maintained 24 as engineered safety features.
And there is still a high
( ')
25 level of credit to be granted such systems.
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But, we are recognizing that there are relatively v
2 small differences in efficiency which can be relaxed to a 3
degree.
4 MR. HULMAN:
We did set a floor as well.
We will 5
not allow standby gas treatment systems to be degraded below 6-90 percent.
7 MR. FIRST:
Well, this is a practical matter.
8 The present standard, or the present 1.52 as you cited 9
requires the new carbon test, which is considerably higher 10 than 90 percent.
11 MR. HULMAN:
Remember, there's considerable 12 uncertainty associated with just the testing, as you're well
()
13 aware.
14 MR. FIRST:
That is in the process of being 15 resolved, as you know.
A new standard has been prepared and 16 is out for committee voting, and so on.
We hope that will 17 be taken care of within this current year.
18 But your statement of course is absolutely 19 correct.
That's been a terrible problem for the last 20 several years.
But what I'm thinking about is this.
We 21 give the plant that 90 percent for the charcoal adsorber as 22 the minimal.
23 Now, the utility doesn't have to buy the type of 24 charcoal that they now get because it doesn't have to meet
()
25 the higher standard, it only has to meet the lower standard.
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'(}V/bc 1
It's obvious they're not going to put in 90 percent because mi 2
then it's going to perhaps degrade.
And in a few months, 3
you'll have to take it out.
4 But supposing they put in 92 percent carbon 5
instead of carbon which tests at 99, as they do now?
Does 6
that help us in terms of assuring that the adsorber will be 7
in good operating condition if it's ever needed.
8 MR. HULMAN:
It sounds to me like the 9
hypothetical case.
You've suggested it would be adequate 10 from a regulatory perspective to have 92 or 93 percent, that 11 might degrade to 90.
It would meet the regulatory 12 guideline, but that's probably adequate because the
()
13 emphasis, as you're well aware, has been on elemental 14 iodine.
15 And we don't think, at this point at least, that 16 that emphasis is well-placed.
17 MR. FIRST:
But that's your only stop for organic j
18 iodides.
This is the only barrier to the emission of l
19 organic iodides.
l 20 Certainly, the suppression pool is taking out l
21 elemental, but you give no credit for organic, which we l
22 agree with.
Now, where else do you get your organic iodides 23 out?
Because you recognize the fact, in fact, some of your i
24 reaction equations show, that organic iodides can be formed.
l
()
25 And we know that in the presence of any organic l
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compound, they readily react to form organics.
x_
I 2
So now we have a source of organic iodide, not 3
nearly as horrible as we thought previously.
And certainly 4
I agree with that.
But we have no other barrier.
5 MR. HULMlgN:
I'm not suggesting that we throw the 6
barrier away.
I'm saying let's put this on the street.
And 7
between now and the time we begin to see applications from 8
licensees for license amendments, we hope we'll have some 9
changes to Reg Guides 1.3 and 1.4 on the street and to 1.52 10 that will address that question directly.
11 MR. FIRST:
Let me just point out one thing 12 that's going to have to come into play.
If you start out
['l 13 with carbon that tests 99.5, or something like that, or t./
14 99.9, and you have a floor of 90, now we have an enormous 15 range over which the carbon can run.
And we have certain 16 intervals that the carbon must be tested.
17 If you now say we don't have any maximum, but we 18 do have a floor, how often are you going to have to test 19 that carbon to make sure you don't go below the floor?
20 Assuming that you have some cheapskate plant operator that 21 wants to buy carbon that's only 93 percent efficient to 22 start out with?
23 MR. HULMAN:
Present requirements, as I remember, 24 are every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> or 18 months, whichever comes first.
()
25 MR. FIRST:
All right.
But do you know that the l
l ACE FEDERAL llEPORTERS, INC.
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I carbon can tolerate that interval without being retested V
2 when you don't have the safety factor of almost 10 percent 3'
available for degrading?
4 MR. HULMAN:
As you're aware, we don't have any.
5 safety factor in the testing requirements for the charcoal.
15 It's just meet the standard.
It's not meet the standard i
7 with an explicit margin.
i 8
If the code committees think that the individual 9
licensee should meet that standard with margin, I'd sure j.
10 like to hear that from the code committees.
l 11 But, at this point, all the staff has done is 12 that meet the standard.
()
13 MR. READ:
There's a margin of a factor of five 14 presently that is explicit in the standard.
I think that 15 what is mostly to occur is that they would load the same 16 charcoal.
But, instead of having to change it out every 18 l
17 months, they would not.
They would be able to keep the 18 charcoal in longer.
19 MR. FIRST:
I understand that's the objective, 20 but certainly nobody objects to savings on resources.
l 21 The only point I'm trying to make, and I guess I
(
22 didn't make it clear enough, is that the intervals for i
I 23 testing were selected on the basis of the current standards j
24 and if the current standards are lowered, is the interval j ()
25 still appropriate?
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That's my only question.
'2 MR. HULMAN:
I can't' answer the question yet 3
because I don't know what kind of changes might be 4
warranted.
First of all, this is a BWR proposal.
5 I don't know whether many of the BWRs -- I guess 6
there'are some older BWRs that don't have the-high filter 7
efficiency requirements.
They're already low today.
8 So any degradation of their capability would not 9
be substantial.
I've got BWRs with no filters.
- 10 MR. FIRST:
No charcoal?
11 MR. HULMAN:
No charcoal, no filters, period.
12 MR. FIRST:
Not just for the control room, but
()
13 for the rest of the plant.
14 MR. HULMAN:
There are some areas of the plant 15 that aren't filtered at all in some of the old ones.
16 MR. READ:
I should think, as it stands now, as I 17 remember, 1.52 says once a month, you turn on the heaters 18 and get rid of the hydroscopic water that you've picked up.
19 I'm absolutely certain that during the summer in Region II 20 there are many charcoal adsorbers there that are essentially 21 no good at all except for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after their monthly 22 dryout.
I would worry more about that, period, than I would 1
23 worry about the 18 months.
24 MR. FIRST:
I agroo with what you're saying, but
()
25 I don't think that makes us happy about this in any way.
ace-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Cmcrage Mn33MM6
0230 08:08 81
{V/bc 1.
MR. READ:' True.
2 MR. FIRST:
If you keep the heaters on long 3
enough, you can drive off whatever is on there and you'll 4
get up to 99.9 percent anyway.
5 MR. HULMAN:
It's a good point.
But if you think 6
the floor that we have set is too low, the 90 percent, or.
7 you think. we ought to reconsider it as a comment, and 8
you've got an. idea of how we can consider it -- because we
{
9 were kind of at a loss -- we'd like to hear about it.
I 10 MR. FIRST:
Yes, I want to think about it.
I t
11 think there's a meeting of the code ap committee coming up i
12 in June.
This may be a question that the committee should 13 look at and give you some advice on, too.
14 MR. HULMAN:
I'd appreciate some knowledge of 15 that meeting.
Maybe we could attend and make a 16 contribution.
17 MR. FIRST:
I will speak to the chairman tomorrow 18 and acquaint him with this point.
If he can't get you on t
4 19 the agenda, I appreciate your offer.
It's going to be in l
20 Nashville, by the way.
21 MR. HULMAN:
Nashville, Seattle, it's only an 22 airplane ride.
23 MR. FIRST:
If there's not going to be an 24 opportunity to have someone make a presentation, at least we i
.O 25 ce" oe' the doc"=e"'
t"'o ht -
ao' ' wit 2 ' ke cece oc i
i Acu FunnRAL RuronTERs, INC.
202 m.)no Nationwide Cmcrage fun.34tMi
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that tomorrow.
v 2
MR. HULMAN:
I appreciate the opportunity.
3 MR. FIRST:
Thank you.
4 DR. MOELLER:
Okay.
I tl. ink we're nearing the 5
wrap-up.
Should we comment at all on Reg Guides 1.3 and 6
1.47 You have obviously acknowledged several times that you 7
recognize that you would like to revise them.
I didn't know 8
whether we should comment on that.
9 MR. HULMAN:
I might suggest that our proposal to 10 revise Reg Guides 1.3 and 1.4 is not before you.
We've only 11 told you of our intent to consider revision, not necessarily 12 to do it.
So it doesn't seem to me that you could comment
()
13 on something you don't have in front of you.
14 DR. MOELLER:
Well, Mol, I think you and I can 15 chat and reach some conclusions on what we say.
- Surely, 16 we'll support revisions and the general approach.
17 MR. FIRST:
I certainly would liko to say that my 18 comments, I hope, are not being taken in a negative way.
I 19 hope you'll consider this as part of our discussion, as 20 points that we'd like to got resolved.
21 MR. HULMAN:
Absolutely.
We appreciato it.
22 MR. FIRST:
I'm delighted with the 23 simplification.
I think it's most admirable that you're 24 looking at it in the way you are.
I support you
()
25 wholohoartedly.
Acil FlilRiRAl. RITOR fl!RS, INC.
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MR. SOFFER:
We have tried to take your comments.
2 We've appreciated the previous comments of yourselves as 3
well as other staff members.
4 DR. MOELLER:
Okay.
With that, let me thank you 5
for spending the afternoon with us and giving us a very 6
beneficial and frank discussion of the issues.
7 And I'll repeat what Mel says:
We're hoping that 8
our comments are helpful to you.
Certainly, we enjoy 9
interacting with you.
10 With that then, I'll declare the' meeting 11 adjourned.
12 (Wheruupon, at 3:35 p.m.,
the meeting recessed,
()
13 to go into executive session.)
14 15 16 17 18 19 20 21 22 23 24 I3 25 l
\\_/
l Acti.Fi!niti<AI. RitroitTiti<s, INC.
I 202 3n noo Nationwide Cmcrage m 3M ud6
CERTIFICATE OF OFFICIAL REPORTER
-(
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of NAME OF PROCEEDING:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON NUCLEAR PLANT CilEMISTRY DOCKET NO.:
PLACE:
WASilINGTON, D.
C.
DATE:
- TUESDAY, MAY 19, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) da/
A (TYPED 5
[
[/
DAVID L. !!OFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
t O
ACRS NUCLEAR PLANT CHEMISTRY SUBCOMMITTEE MEETING PAY 19, 1987 SRP REVISIONS 6.5.2'
.CONTAINMEllT SPRAYS AS FISSION PRODUCT CLEANUP SYSTEMS 6.5.5 SUPPRESSION POOLS AS FISSION PRODUCT CLEANUP SYSTEMS O
NRC STAFF MEMBERS.
LEN SOFFER JAC0l!ES READ JERRY HULMAN O
i f}
i PRESENTERS LEN SOFFER
- SECTION LEADER, SEVERE ACCIDENT ISSUES BRANCH, RES
- RATIONALE DISCUSSION
[
JACQUES READ
- SENIOR REACTOR SYSTEMS ENGINEER, SEVERE ACCIDENT ISSUES BRANCH, RES
- TECHNICAL BASES DISCUSSION I
JERRY HULMAN
- CHIEF, SEVERE ACCIDENT ISSUES BRANCH, PES l
()
- REGULATORY IMPLICATION DISCUSSION l
i i
f
lO HISTORY >
l 3962
- PART 100 & TID 14844 ISSUED 1972
- SRP ISSUED, REVISED TWICE 1985
- STAFF PLANS FOR IMPLEMENTING SOURCE TERM RESEARCH j
DISCUSSED WITH ACRS 1986
- SECY 86-76 PRESENTED TO COMMISSION N!UE Pb$I MENT, THE FIRST
~
IMPLMENTAT10MPESULh8 6
l 1987
- AL!
BU" A FEW POWER REACTORS IN U.S. HAVE RECEIVED lO OPIRAT NG LICENSES l
I l
l l
O
r f=
m POTENTIAL SOURCE TERM CHANGES NEAR-TERM INTERMEDIATE
- LONG-TERM REVISED TREATMENT EMERGENCY PLANNING
- SITING OF ACCIDENTS IN EIS REMOVAL OF SPRAY CONTAINMENT LEAK RATES
- ACCIDENT ADDITIVES (PWR)
AND INTEGRITY MONITORING SUPPRESSION P0OL ENVIRONMENTAL QUALIFICATION CREDIT (BWR) 0F EQUIPMENT SAFETY ISSUE EVALUATION L
CONTROL ROOM llABITABILITY AND AIR FILTRATION SYSTEMS
- STAFF STUDIES PROCEED IN PARALLEL WITH NUREG-IISO, BUT NO CllANGES UNTil AFTER ISSUANCE OF NUREG-1150, q
L
r O
STANDARD REVIEW PLANS INVOKED BY DBA LOCA DOSE EVALUA110N o
6.5.2 CONTAINMENT SPRAY AS A FISSION PRODUCT CLEANUP SYSTEM o
6.5.3 FISSION PRODUCT CONTROL SYSTEMS AND STRUCTURES O
o 6.5.4 ICE CONDENSER AS A FISSION PRODUCT CLEANUP SYSTEM o
15.6.5A RADIOLOGICAL CONSEQUENCES OF A DBA-LOCA FROM CONTAIN-MENT LEAKAGE o
15.6.5B LEAKAGEFROMENGINEEREDSAFETYCOMPONENTSOUTSIDE CONTAINMENT 0
15.6.5D LEAKAGE FROM MAIN STEAM LINE ISOLATION VALVE LEAKAGE CONTROL SYSTEM (BWR)
O OTER SRPs ARE RELATED
SRP 6,5,2 - PRESENT VERSION o
BASED ON TID-14844 o TIMING-RAD 10ACTIVilY IN CONTAINMENT AT T=0 0 COMPOSITION - NOBLE GASES AND 10 DINE ONLY T
10 DINE IS PRIMARILY ELEMENT L (1 )
2
[
o SPPAY ADDITIVE STRONGLY ENC 0URAGED, IF PRESENT, REQUIRED TO BE INJECTED AUTOMATICALLY o
LOW IODINE REMOVAL CREDIT UNLESS SUMP PH AB0VE 8.5 o
NO EXPLICIT MODELS FOR SPRAY REMOVAL COEFFICIENTS OR PLATE 0VT AND DEPOSITION I~)
l O
OVERVIEW f
PROPOSED REVISION OF SRP 6.5.2 l
BACKGROUND:
o ONE OF THE SHORT-TERM CHANGES DISCUSSED IN SECY 86-76
?
PROPOSED CHANGES o
REMOVES EMPHASIS ON IMMEDIATE INJECTION OF SPRAY ADDITIVES t
t o
RETAINS POST-ACCIDENT SUMP PH CONTROL, BUT AT LOWER PH LEVEL
~
O o
EXTENDS EvAttiATiON 0s SeRAY TO OTHER PISS 10N eR0 DUCTS, IN ADDITION TO IODINE.
OTHER ASPECTS o
$0T-DEPENDENT ON PARTICULAR SOURCE TERM INSIDE CONTAINMENT, CAN BE USED WITH TID-14844,OR POTENTIAL REVISION f
I o
NO LICENSEE ACTION REQUIRED i
i SllMMARY - REPRESENTS RELAXATION WITH NO SIGNIFICANT DETRIMENT TO SAFETY, BUT COST SAVINGS 70 INDUSTPY
!O I
4 i
E=
L
s SFP 6.5.2:
CONTAlfiMEt'T SPRAY AS A FISSION PRODUCT CLEANUP SYSTEM HEVISIONS o
DELETE REQUIREMENTS FOR SPRAY ADDITIVE DURING ]NJECTION AND FOR AUT0t1ATIC ADDITION o
EASE SUMP PH CONTROL ON NEED TO KELP 10 DINE REVOLATILIZAl10N AT VERY LOW LEVEL o
REMOVE TID-14844 SOURCE 1ERM, REPLACING THIS BY RtFERENCE TO REG, GUIDES 1,3/4 o
PROVIDE EXPLICIT t10DELJ FOR ISOTOPES OTliER TliAN 10D!f;ES (SOLID FISSION F,P )
o PROVIDE EXPLICIT MODELS FOR NAT11RAL DEPLET!0f; (PLATEUUT, WALL DEPOSITION) o PERMIT VARIETY OF SPRAY SYSTEMS TO BE REVltWED (E.G., BWR SPRAYS) 0 If1ETE PROCEDIFES FOR FfVIDiltiG ltfFFECTlW ADDITlW SYMEfC l C
PASES FOR PROPOSED CHAP.'GES 0
RE-EVALUATION OF U.S., JAPANESE AND ITALI AN EXPERit'ENTS INDICATE THAT INITIAL REI'0 VAL 0F ELEMENTAL IODINE PY UNRECIRCULATED SPRAY SOLUTION IS VIRTUALLY INDEPENDENT OF PH, HENCE, ADDITIVES NOT NEEDED DURING SPRAY INJECTION, o
DATA INDICATE PH OF 6 OR GREATER KEEPS 10 DINE RE-EVOLUTION IN SUMP SOLUTION AT VERY LOW LEVEL (SMALL COMPARED TO ORGANIC 10 DINE),
NO SIGNIFICANT DIFFERENCE IN 10 DINE RE-EVOLUTION
(])
OBSERVED AT PH 9 VS, PH 7.
o ALLOW SEVERE ACCIDENT INSIGHTS REGARDING SPRAY EFFECTIVENESS FOR OTHER FISSION PRODilCTS (BESIDES 10 DINE) TO BE REFLECTED IN SPP.
o
x ADDITIVES DELETED FROM SRP 6,5,2 I
TH10 SULPHATE UNSTABLE CAUSES SULPHUR ENBRITTLEMENT OF NICKEL ALLOYS k
f PYDRAZINE T
OXlDIZED READILY LY AIR
(
/~x
,/~
I O
SPRAY EFFECTIVENESS INDEPENDENT OF ADDITIVE CONCENTRATION l
r
- l. -
UNIVERSITY OF PISA FOUND N0 SIGNIFICANT DIFFERENCE BETWEEN TAP SOLUTION i
WATER AND 1% NA 8 0223 l
JAERI FOUND 10 DINE REMOVAL COEFFICIENT NOT SIGNIFICANTLY DEPENDENT UPON PARTITION COEFFICIENT l
l RE-EXAMINATION OF U.S. EXPERIMENTS CONFIRMS F0PEIGN OBSERVATIONS k
l
- O 1
4 i
i l
t i
3 i
IODINE CHEMISTRY WITHIN CONTAINMENTS HYDROLYSIS
!~ + H+ 4 H01
- FAST 12*U0
=
2 103 + 51~ + 6H+
- SLOW 312 + 3H 0
=
2 CATALYSIS
- PER0XIDE DECOMPOSITION 21~ + 2H+ + O2 H022+I2
=
H02 2 + 2H+ 21~
=
2H 0 + 1 p
2
- METHANE OXIDATION c
CH 1 + HI CH4+12 3
=
- H O
=
3 2
3
- liYDROGEN COMBUSTION 2HI H2+12
=
217+2Ho 02 + 4H1
=
p i
O RADIOLYSIS EFFECTS WATER DECOMPOSITION 2.7E- + 2.70H + 3.4H+ + 0.70H+
4.9 H O
=
2 0.45Hp + 0.75 H 02 2 + 0.6H NITROGEN FIXATION NITROUS, NITRIC ACIDS N'HO NO, N0
=
=
2 2
2 8
PH3 10 RADS
=
10 DINE REACTIONS FOR PH < 4 AND !!) > 10-6, y PRODUCED g
2
~
PRODUCED FOR 6 4 PH < 9,103 i
l i O
i r
O PH0 POSED IMPLEMENTATION FOR SRP 6.5.2 o
NU CHANGE REQUIRED FOR PRESENT PWR'S LICENSEES HAVE CH01CL OF t
USING AUTOMATIC ADDITION OF SPRAY ADDITIVES MANUAL ADDITION (ON HIGH RAD. SIGNAL, FOR EXAMPLE)
O NO ADDITIVES (BUT ASSURE PH CONTROL IN SUMP) o CAN USE WITH EXISTING TID-14844 SOURCE TERM OR NEW SOURCE TERMS 10 BE GIVEN IN REVISED R G. 1.3/1,4 l
l i
l lO l
i l
l l
l
4 O
i PROPOSED SRP 6.5.2 REGULATORY IMPACTS i
53 PWR UNITS USING NA0H t
i 2 PWR UNITS USING N H
2 4
IN ICE 9 PWR UNITS USING NAB 047 7 PWR UNITS USING TSP FOR PH CONTROL i
NO PERCEIVED CHANGE IN PUPLIC RISK 1
i e
!. O l
i l
l l
i i
l
!!O i.
i l
I l
O-SRP 6.5.2 OTHER IMPACTS
- 1. NO PERCEIVED CHANGE IN PUBLIC RISK
- 2. REDUCED ~ PERSONNEL HAZARDS IN MAINTENANCE a OPERATION
- 3. PEDUCED CAUSTIC EQUIPMENT EXPOSURES FROM INADVERTENT r
ACCUATIONS
- 14. RELATIVELY SMALL HARDWARE CHANGES
- 5. P0TENTIAL ELIMINATION OF A MAINTENANCE CONCERN FOR NA0H PLANTS (53 PWR UNITS)
O
- 6. STAFF RESOURCES TO REVIEW LICENSE AMENDMENTS - SMALL O'
%NM e
O
= - - _ -.
)
SUPPRESSION POOLS AS FISSION PRODUCT CLEANUP SYSTEMS
- PRESENT STATUS o
REGULATORY. GUIDE 1.3 - NO POOL CREDIT TO BE GIVEN.
1 c
SRP 6.5.3 STATES THAT POOL CREDIT MAY BE GIVEN, BUT GIVES N0 PROCEDURES OP CRITERIA FOR DOING S0, o
SRP 6.5.1, CRITERION V, PERMITS CHARC0AL FILTRATION UNITS
-(])
TO BE NON-ESF IF 4 90% IODINE EFFICIENCY, t
O GESSAR-II REVIEW ALLOWED POOL CREDIT FOR SEVERE ACCIDENT RISK EVALUATION, C )-
/*-
t/
STANDARD REVIEW PLANS INV0KED BY DBA LOCA DOSE EVALUATION o
6.5.2 CONTAINVENT SPRAY AS A FISSION PRODUCT CLEANUP SYSTEM.
o 6.5.3 FISSION PRODUCT CONTROL SYSTEMS AND STRUCTURES.
o 6.5.4 ICE CONDENSER AS A FISSION PRODUCT CLEANUP SYSTEM.
PROPOSED o
6.5.5 PRESSilRE SUPPRESSION POOLS AS FISSION PRODUCT CLEANUP
- SYSTEMS, o
15.6.5A RADIOLOGICAL CONSEQUENCES OF A DBA-LOCA FROM CONTAIN-MENT LEAKAGE.
~
'o 15.6.5B LEAKAGE FROM ENGINEERED SAFETY COMPONENTS OUTSIDE CONTAINMENT.
0 15.5.5D LEAKAGE FROM MAIN STEAM LINE ISOLATION VALVE LEAKAGE CONTROL SYSTEM (BWR)
OTWR SRPs ARE RELATED O
/:
kJ OVE5 VIEW PROPOSED NEW SRP 6.
5.5 BACKGROUND
o ONE OF THE SHORT-TERM CHANGES DISCUSSED IN SECY 86-76.
MAJOR ASPECTS PERMITS CREDIT FOR' SUPPRESSION P0OLS AS FISSION PRODUCT CLEANUP; o
- SYSTEMS, CONSERVATIVE DECONTAMINATION FACTORS (DF) ALLOWED WITH NO APPLICANT ANALYSIS.
SUPPRESSION POOL BYPASS-LEAKAGE TO BE ACCOUNTED FOR IN DOSE CAL-0 CULATIONS.
n
\\>
EXISTING ESF FILTRATION SYSTEMS NOT TO BE DEGRADED BELOW MINIPUM 0
VALUE (90%) 0F REG. GUIDE 1.52 (REV 2).
0THEP ASPECTS NOT DEPENDENT ON PARTICULAR SOURCE TERM INSIDE CONTAINMENT o
CAN BE USED WITH TID-1484410R POTENTIAL REVISION.
o NO LICENSEE ACTION REQUIRED.
SUMMARY
- REPRESENTS RELAXATION WITH NO SIGNIFICANT DETRIMENT TO
~
SAFETY.
O
P 4
C 1
BASES FOR PROPOSED SRP 6.5.5 CHANGES o
SPARC CODE TIME-AVERAGED DECONTAMINATION FACTOR CALCULATI0t'S FROM NUREG-1150, POOLSCRUBBING.
o G.E., BRITISH, SWEDISH AND PNL EXPERIMENTS ON I2
}
~
o KNOWN CHEMISTRY OF HYDR 0 GEN IODIDE.
i LO I
I e
O T=$*--
+ev%*T"9"*
e w - P r ?'P 9Tw P=
@N*w"-'=-r"eeWetv.w M-=-%-----tr-,.
T--rNPT-P-T=we-wen
>ar We r M
- N G."mwfWW W'*tW'-
9M-T FM--'fr=N~&T-P7"
()
Ef fective (Time Averaged) In Vessel Release.Decontapination Factors for the Suppression Pool (Peach Bottom t'. ark 1)
In-Vessel 0F Fission Product Group TB1 Sequence TC2 Sequence Large*
200 CSI 300 Large C50H 250 Large Te
- 0ue to inconsistencies in the reported values, an exact quantification is not possfole.
Ef fective (Time.' Averaged) Ex-Vessel Release Decontamination Factors for the Suppression Pool (Grand Gulf Mark !!!)
\\
Fission Product Group TC Sequence TB1 Sequence T82 Sequence CsI 85 50 60
'Cs DH 80 55 65 Te 40 40 50 Ex-Vessel 0F Fission Product Group l
25 Sr 20 Ba 15 La 30 Ce 10 Te llO
~o a n G-t;t 5 10' l
t<
o o
4 >
i k
(
10' o
i,
l(a L
50 o
t u
2 m10 o
a o
=
o
- o. f
~
o 10, to o
j p p
/ /o 4
l 3
' ""I
""I
' ' ' " "I 10 10 10' 10 10' 10 Calculated DF Model Data Comparison After Addition of Inertial Oposition Models and Experimental Constant Optimization
-g
=
--.w, y
g 9,, *--
-,,--v-3w------,y,.-wv.
w-y-
-,,q.-m------w-----
.w-g
O O
n o.-
CASE 4A DECONTAMINATION FACTORS 10000 E
F l
(U 1
{}b r
c 1000-l p
g a
o A
o F
d
~
z 4
O
(
4 4
10 0-Y\\
I Z
J
\\
8 8
O
~
10_
1 l
0 lb0 2b0 3b0 4b0 Sb0 6b0 7b0 800 TIME (min)
FIGURE 6.8.
DECONTAMINATION FACTORS FOR LARGE ELLIPTICAL BUBBLES l
Q 10*
^
7 O
i 31 i
g i
.I
~
l I
i l
I I
10' :-
I I
I
~
1 T
I I
i
,l l
I l
El I;.
m ci 10' --E I I2 IE E
=l
~
5I
!5
.Csl
'2 5
E 01 I S E
.cl Iu O
i E 10* :- E l li
=i 1
i=
i I.
4l a
l l
I
~
I l
' ~
I 3
i
.10 l
g l
l g
i I
CH31 I
~
~
~
I I
10 o
11 1
l 130 135 140 145 150
,'155 160 165 170 Accident Time, min DECONTAMINATION FACTORS FOR IODINE SPECIES INTEGkETED OVER THE CORE MELT PERIOD.
THE CsI CURVE REPRESENTS CASE 1, THE I2 CURVE REPRESENTS CASE 2 AND THE CH I CURVE IS THE SAME IN ALL CASES
=
3 o
l l
l l
'%./
SirPPPFSSION POOL BYPASS NOT ALL FISSION PP0 DUCTS G0 FROM DRYWELL THRU SUPPRESSION POOL, o
SMALL FRACTION (TYPICALLY, FEW PEPCENT) BYPASSES POOL.
FRACTION THAT BYPASSES POOL IS UNSCPUBBED.
O NEED TO ACCOUNT FOR POOL BYPASS'IN STAFF ASSESSFENT OF o
CONSEQUENCES.
oV O
l r~'s l G l
4
,V SUPPRESSION POOL PARAMETERS TYPE VOLUME SUBMEPGENCE OF 3
(FT )
DOWNCOMERS, FT MARK I 120,000 3-4 MARK !!
160,000 10 - 15 cx V
MARK IIi 160,000 8.5 - 13 I
U
DEFAULT DF VALUES IN PROPOSED SRP 6.5.5 i
DF = 1 FOR NORLE GASES, ORGANIC 10DIDES CH I)
)
(XE, KR, 3
f DF = 10 FOR PARTICULATE I0 DINE, OTHER AEROSOLS (MARK II AND III) 5 FOR PARTICULATE IODINE, OTHER AEROSOLS (MARK 1)
T
=
=
L DF = 10 FOR ELEMENTAL '0 DINE (1 ) (PARK II AND III) 2
,,U 5 FOR ELEMENTAL I0 DINE (1 ) (MARK I)
=
2
\\m. /
- e O
PROPOSED SRP 6.5.5 CHANGES REGULATORY IMPACTS
- 2. PDTENTIAL RELAXATIONS IN PERFORMANCE REQUIREMENTS FOR BWR MITIGATIVE ESFS (TECH SPEC 8 TESTING REQUIREMENTS)
- 3. PRIMARY ESF CANDIDATES FOR CHANGE:
A) CONTAINMENT, LEAK RATE TESTING (CRGR SUGGESTS THAT THIS SRP CHANGE NOT BE USED AT THIS TIME)
B) SGTS a OTHER FILTERS, TESTING REQUIREMENTS
(])
C) CONTAINMENT SPRAYS, FLOW RATES 8 INITIATION TIMES (P0TENTIALLY)
D) MSIV/LCS TESTING REQUIREMENTS E) CLOSER SCRUTINY OF BYPASS
- 4. STAFF RESOURCES TO REVIEW LICENSE AMENDMENTS - SMALL l
0 I
l