ML20215H397

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Rev 1 to Procedure R-0775, Facility Change Safety Analysis
ML20215H397
Person / Time
Site: Rancho Seco
Issue date: 04/15/1987
From:
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20215H387 List:
References
R-0775, R-775, TAC-64735, NUDOCS 8704200302
Download: ML20215H397 (18)


Text

i PAGE 1 OF 3 i

i FACILITY CHANGE SAFETY ANALYSIS ECN R-0775 REY. 1 AND LOG NO. 807 E, G SUBS R-0775 A-I REY. O Descrintion:

Perform excavation for a new sump, a new Regenerant H.oldup Tank (RHUT), and buried piping and conduit required to implement all the changes.

Backfill and pave as, required.

Add a make-up demineralizer waste sump, two sump pumps, and discharge header from the pumps.

Make-up demineraliser regenerant wastes and other non-radioactive wastes will be routed to the new sump.

The new make-up demineraliser will be lined with High Density Polyethylene (HDPE).

Upgrade existing RHUT

'A'

'B' transfer pump impeller and add a parallel pump to improve water movement capabilities of REUTs

'A'

'B'.

Install a third pump for the new REUT ('C').

Provide foundations for the new RHUT, new pumps, demineraliser skids, and effluent strainer skid.

Add a ~100,000 gallon REUT and designate it the

'C' RHUT (T-9500).

Tank will be lined with HDPE and will have a mixing agitator, sampling pump, level indication, and acid and caustic supply for neutralization.

Add an off-line oil separation / filtering system that connects between the condenser pit sump and polisher sump.

Install a new sluiceable demineraliser system which will function to clean up RHUT

'A'

'B' water prior to transfer to the retention basins.

Install all interconnecting piping required to accommodate the changes specified in ECN R-0775 Rev. 1 (See sketch of interconnecting piping, Attachment I).

Reroute secondary sample waste discharge to the polisher sump where a sampling basin will be provided.

Reroute secondary sample cooler service water to the new make-up sump.

Reroute other potentially contaminated secondary drains to the polisher sump.

Provide all necessary wiring needed to connect the new pumps, RHUT equipment, sluiceable demineraliser equipment, and effluent strainer to plant power sources and local control panel H4RH.

I Replace the existing H4RH panel with a new H4RH human factored control panel that integrates new and old controls (See ECN R-0775 i

Major Rev.

1, Sub ECNs A through I Rev.

O, and DBR) l

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PAGE 2 OF 3 Reason ing Channe:

ECN R-0775 Rev. 1 and sub ECNs A through I provide modifications necessary to separate potentially contaminated from non-contaminated secondary waste water, increase the plant's processing capability and flexibility, and provide additional cleanup components which will be used to maintain off-site liquid effluent discharges within 10 CFR 50 Appendix I limits.

Also, the modifications will improve the plant's ability to safely process and dispose of waste water following an OTSG tube leak.

The changes represent an operational enhancement and an improvement in radiological safety and control.

Evaluation and Basis 12I Safety Findinas:

All the new mechanical equipment, piping, valves, and power scurces are non QA and Seismic Class I and are designed in accordance with project specifications and required codes of the effected systems.

The new Make-up Demineralizer Sump and the new

'C' RHUT will not contain radioactive wastes and thus will not be controlled by radioactive waste management systems design requirements (Reference DBR for ECN R-0775).

The make-up demineraliser sump and pumps collect non-radioactive wastes separate from polisher and condenser pit sump wastes which become radioactive following OTSG tube leaks.

The new

'C' RHUT will be used to store and neutralise waste water from the make-up sump.

The existing

'A'

& *B' RHUTs will be used to store and neutralise condenser pit and polisher sump wastes.

Also, excess tritiated Demineralized Reactor Coolant Storage Tank (DRCST) water can be transferred to the

'A' and

'B' RHUTs.

A new sluiceable demineraliser system will clean up A & B RHUT waste water prior ta discharge to the retention basins.

The non-radioactive

'C' RHUT waste water is neutralised prior to release.

The discharge will not be through the sluiceable demineraliser, the effluent strainer, or radiation monitor R-15020.

In contrast RHUT

'A'

'B' waste water is always monitored by R-15020 when discharged to the retention basins.

The

'A'

'B' RHUTs cannot be discharged at the same time.

One of the two tanks will always be maintained as.a receiver at all times.

The new

'C' RHUT' water,can be transferred to the

'A' or

'B' tank, but

'A' or

'B' tank contents will not be transferred to

'C' to avoid contaminating

'C' waste water.

Hydrostatic testing, leak testing, and testing against component specifications are required.

New equipment will be similar to the existing equipment to optimise maintenance procedures and spaie parts inventories.

Plant operating procedures will be revised to include the operation of the new ccmponents and their interactions with the existing systems.

_ _ = _ _ _

PAGE 3 OF 3 2

t Use of HDPE affects the Fire Protection Program.

HDPE is a flammable material.

The sump and tank being installed are located outside the south side of the turbine building.

The FHAR and the Combustible Loading Calc. will be revised to include the HDPE being added by this change (See Attachment II).

USAR Chapter 11 " Radioactive Waste and Radiation Protection" will be reviewed against the changes being made and a complete rewrite i

of Chapter 11 submitted for the next FSAR update.

Tech Spec section 6.17 does apply to the change.

A detailed discussion of the major changes to the radioactive waste management system will be included in the next FSAR update.

The discussion will include the topics outlines in Tech Spec section 6.17.2A.1 a through h (See Tech Spec 6.17, Attachment III).

No other Tech Specs are affected by the change.

The changes do not alter Rancho Seco's design basis.

Release of

. radioactive liquids is expected following the abnormal operating condition of primary to secondary leaks.

The modifications will increase the possible amount of radioactivity entering into the

'A'

'B' RHUTs by ~40%, but the volume of radioactive water being i

processed is reduced sharply.

Also, the new processing equipment being installed works to remove significantly more radioactivity j

than the previous system.

Ultimately, the total amount of radioactivity released annually is controlled by the ALARA limits of 10CFR50 Appendix I.

The change will not cause the amount of i

radioactivity being released off-site as liquid effluent to increase.

A rupture of either tank and subsequent release of radioactivity will not result in a release above 10CFR50 Appendix I limits.

The changes act to give Operations better control of the radioactive waste water systems.

Management of waste water is improved and thus nuclear safety is also improved.

The modifications will not affect,previously analyzed plant faliure modes, and no new failures are intr'oduced by the changes.

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Attachment Jr 1:30 Daoe 1 of i FIRE PR ION CONTROL REPORT 8

NEFPCR No.L-no433

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Date Received __ -l V-M beI Part I - Descriotion:

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No effect on the fire protection program.

M ire Protection Program affected as follows:

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f.Sttrit-y Affected FP documents:

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Note reasons in above etion.

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G,l Attackt ni w us PANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.17 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS (LIQUID, GAbr.Uu3, ANU 5ULID) 6.17.1 Function The radioactive waste treatment system (if quid, gaseour, and solid) are those systems described in the facility Final Safety Analysis Report or Hazards Summary Report, and amendments thereto, which are used to maintain that contro1 over radioactive materials in gaseous and liquid effluents and in solid waste packaged for offsite shipment i

required to meet the LCO's set forth in these Specifications.

6.17.2 Major changes to the radioactive waste systems (liquid, gaseous, and solid) shall be made by either of the following methods.

For the purpose of this specification, " major changes" is defined in Specification 6.17.3, below.

A.

Licensee-initiated changes:

1.

The Commission shall be infomed of all changes by the l

inclusion of a suitable discussion of each change in the l

Annual FSAR Update for. the period in which the changes were made. The discussion of each change shall contain:

-=- t a.

A sumusary.of the evaluation that led to the determination that the change could be made (in accordance.with 10 CFR 50.59);

b.

Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; c.

A detailed description of the equipment, components, and processes involved, and the interfaces with other plant systems; d.

An evaluation of the change which show:s the predicted l

releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste from those previously predicted in the license application and amendments thereto; e.

An evaluation of the change which shows the expected maximum exposures to individuals at or beyond the SITE BOUNDARY and to the general population from those previously estimated in the license application and amencments thereto; 4

Amendment No. 53 5 '9

p%e a a 3 53>

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.17.2 (Continued) f.

A compaH son of the predicted releases of radioactive mateMals in liquid and gaseous affluents and in solid waste to the actual releases for the peM od in which the changes were made; g.

An estimate of the exposure to plant operating personnel as a msult of the change; and h.

Documentation of the fact that the change was reviewed and found acceptable by both the PRC and MSRC.

2.

The Change shall become effective upon review and acceptance by both the PRC and MSRC.

6.17.3 Background and definition of what constitutes " major changes" to radioactive waste systems (liquid, gaseous, and solid).

A.

Background

1.

10CFRPart50[Section50'.34a(a)requiresthateach

..g application to construct a nuclear power reactor provide a

,e descMption of -the equipment installed to maintain control over. radioactive mateMal in gaseous and liquid effluents produced duMng nomal reactor operations, including operational occurrences.

2.

10 CFR Part 50, Section 50.34a (b) (2) requires that each application to construct a nuclear power reactor provide an estimate of the quantity of radionuclides expected to be released annt. ally to unrestricted areas in liquid and gaseous effluents produced during nomal recctor operation.

3.

10 CFR Part 50, Section 50.34a (b) (3) requires that each application to construct a nuclear power reactor provide a description of the provisions for packaging, storage, and shipment offsite of solid waste containing radioactive materials resulting from treatment of gaseous and liquid effluents and from other sources.

4.

10 CFR Part 50, Section $0.34a (c) requires that each application to operate a nuclear power reactor shall include (1) a description of the equipment and procedures for the contro' of gaseous and liqui 1 effluents and for the maintenance and use of equipment ins:alled in radioactive waste systems, and (2) a revised estimate of the infomation required in (b)(2) if th: expected releases anc excosures aiffer significantly from tne estimate sucaittac in :ne :onstruction gemit.

ameacent Nom 52

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.17.3 (Continued) 5.

The NRC's Safety Evaluation Report and Amendments thereto issued prior to the issuance af an operating license contains a description of the radioactive waste systems installed,in the nuclear power reactor and a detailed evaluation (including estimated releases of radioactive materials in liquid and gaseous waste and quantities of solid waste produced from nomal operation, estimated annual maximum exposures to an individual in the unrestricted area and estimated exposures to the general population) which shows the capability of these systems to meet the appropMate regulations.

6.

The NRC's Final Environmental ^ Statement issued prior to the issuance of an operating license contains a detailed evaluation as to the expected environmental iapact from the estimated releases of radioactive mateHal in liquid and gaseous effluents.

B.

Definition

" Major Changes" to cadioactive wasta systems (liquid, gaseou's, and solid) shall inplude the following:

s 1.

Major changes in process equipment, components, structures, l

and effluent monitoHng instrumentation from those described in the Final Safety Analysis Report (FSAR) or the Hazards Summary Report and evaluated in the NRC's Safety Evaluation Report (SER) (e.g., deletion of evaporators and installation of demineralizers; use of fluidized bed calciner/ incineration in place of cement solidification systems);

2.

Major changes in the design of radwaste treatment systems (liquid, gaseous, and solid) that could significantly alter the characteristics and/or quantities of effluents released or volumes of solid waste stored or shipped offsite from those previously considered in the FSAR and SIR (e.g., use of asphalt system in place of cement);

3.

Changes in system design which may invalidate the accident analysis as described in the SER (e.g., changes in tank capacity that would alter the curies released); and 4.

Changes in system design that could potentially result in a significant increase in occupational exposure of operating person 1el (e.g., use of skid-mounted equipment, use of mobile processing equipment).

Amendment No. 53 6-21

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OESIGN BA' SIS RE PQRT

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Nuclear / Mechanical

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L PURPOSE OF QESIGN CH ANGE:

See Attached.

11. DESIGN CRITERI A USED:

See Attached.

111. CALCULATIQNS & QESIGN INFORM ATION:

See Attached.

IV. FAILUR E MODES:

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SPECIAL MAINTENANCE REQUIREMENTS See Attached.

3F.

V I. SPECI AL QPERATING REQUIREMENTS:

l See Attached.

l Vll. VERIFICATION. CRITERI A See Attached.

Vill. COMMENTS :

See Attached.

lx. APPROVALS :

See Attached.

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g DESIGN BASIS REPORT gust 11, 1986 DBR Rev. No.

0 This DBR is Based on:

Date:

ECN R-0775 A 'through I, Rev. O MOD No.

530 Work Order No.

108530 NCR No.

I.

PURPOSE OF DESIGN CHANGE:

i 10CFR50 Appendix I establishes the limits on total annual dose to the public from normal plant release points. The lower limits of detection (LLD) for radioactivity and the volume of contaminated water discharged are prime factors in determining the offsite dose.

By segregating potentially. radioactive sources from non-radioactive sources", the differential between actual radioactive concentration and the LLD is reduced.

This design change will provide Leproved facilities for segregating, processing, and disposing of potentially radioactive waste water.

i II.

DESIGN CRITERIA:

A.

S_ummary of Change A new sump (seke-up domineralizer. sump) and pumps shall be a

provided to collect make-up desineraliser regenerant wastes and other non-radioactive wastes separately from the polishing e

domineraliser regenerant wastes and the condenser pit sump wastes which become radioactive following once through steam generator (OTSG) tube leaks.

l l

A'new make-up domineralizer regenerant hold up tank (RHUT) T950C will be provided to store and neutralize the waste water transftrred from the make-up desineralizer sump prior to transfer to the retention basins or the bypass line for off-site discharge.

The two existing RHUTs T950A and T950B shall be used to store and neutralize wastes from the condenser pit sump and the polishing demineralizer system sump. Also, excess demineralized (triciated) reactor coolant can be transferred from storage tank T621 to these RHUT's for discharge.

A new regenerant waste transfer pump shall be provided for the new regenerant hold up tank. Also a new regenerant waste transfer pump shall be provided as a spare to the existing pump, servicing RHUT's T950A and T9508.

A sluiceable demineralizer system shall be provided to process contaminated waste water held in RHUT's T950A and T950B prior to discharge to the retention basins.

l 3231V 1

f.

s DESIGN BASIS REPORT Oily. wastes will te reecvec primartiy at sne concenser pit sump oy means of an off line pump that will transfer surface oil to a disposal crum.

The first exchange vessel in the sluicing demineralizer system will contain an activateo charcoal cec for capture of emulsified oil that escaped from the condenser pic sump.

Piping additions and modifications shall be made as required for the new equipment and waste stream segregation.

The available system flow naths (Figure 1 attacheq) are as follows:

1.

Flow may be from the makeup deminerait:er surp through sump pumps P966A and 6 to RHUT TS50C.

Optionally, the f1cu path can be to RHUT T950A or RHUT T9508.

2.

Flow may be from RHUT ToSOC through regenerant waste transfer pump P683C via the sotra drains to the north or south retention basins or the bypass line to Hadselville Creek.

Optionally, the tank cay be gravity drained through the pump bypass 1 ne.

The discharge flow from RHUT'T950C will be never be through the sluiceable demineralizer and will never be through the effluent strainer. The discharge flow from RHUT T950C will not be monitored by radiation monitor R-15020.

3.

Flow may be from the polishing dominerlizer sump (polisher sump) through sump pumps P965A and B to.RHUT T950A or RHUT T9508.

The polisher sump discharge flow will never be to RHUT T950C.

l 4.

Flow may be from RHUT T950A through the effluent strainer (gravity drain), through the sluiceable demineralizer booster pump, through the sluiceable demineralize.r to RHUT T9508 This flow path can also be frcr RHUT T9508 to RHUT T950A.

The demir.iralized waste flow path will be from RHUT T950A or RHUT T950B through transfer pumps P683A or P6838 to the north or south retention basin.

The discharge from RHUT 7950A or T9508 to the retention basins is always monitored by radiation monitor R-15020.

5. ' Flow may be from RHUT T950A or RHUT T950B through the regenerant transfer. pump P683A or P6838 through the effluent strainer to the north or south retention basins.

the discharge flow is always j

monitored by radiation monitor R-15020.

RHUT T950A and RHUT T9508 cannot be discharged simultaneously since one tank must be maintained as a received at all times.

The effluent strainer may be bypassed with flow through pump P683A or P6838 to the north or south retention basins.

1 i

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4 DESIGN BASIS REPORT 6.

Flow may be from RHUT T950A or RHUT T950B through the effluent strainer through the domineralizer booster pumps to the spent regenerant tank T689A or T6895.

]

7.

Flow s.ay be from the domineralized reactor coolant scorage tank T621 to RHUT T950A or RHUT T9508 but never to RNUT T950C.

B.

Desian Basis The design will be in accordance with project specifications, and standards for the effected systems.

Regulatory Guide 1.143, Revision 1, Design Guidance for Radioactive Waste Management Systems Structures, and, Components Installed in Light Water Cooled Nuclear Power Plants is applicable to those nE systems containing/ processing radioactive waste. The make-up domineral:.zer sump and the new RHUT T-950-C do not contain radioactive waste and therefore are not designated per R.G. 1.143.

C.

S.s.sna The scope of this change includes the clean drain system, the secondary waste water disposal system, the domineralized reactor coolant st:srage system, the make-up water domineralization system, the polishing domineralizer system, and the secondary sample system.

Plant operating procedures for the above systems that are affected'by this change will be revised.as necessary.

D.

Eauinment ': lass and Power Requirements The equipment classifications and power requirements are sunnarized j

below:

i Mechanical Equipment Proiect Class Codes l

1.

RHUT, T950C 339 API 650 2.

Regenerant Waste 337 Hydraulic Institute Transfer Pump, P683 A,B,C 3.

Make-Up Domineralizer 337 Hydraulic Institute Sump Pumps I

4 RHUT T950C Waste 337 Hydraulic Institute Samp1e Pump 5.

RHUT, T950C Agitator 339 3

DESIGN BASIS REPORT

f. ' Slui : b!: 02:' :ra!':er

^25 ASPE Sectica VIII Systen 01c*r-and ve.1vne The transfer piping ano valves from domineralized reactor coolant storage tank to RHUT's T-950A and B is Project Class 22 and

'abricated cer ANSI S31.1.. NOTE: The existing system is 22N3, yhich per current standsrds is treated as 22.

All otner piping ano valves for these enanges are Project Class 239 1

and fabricated per ANSI 331.1.

Power Source Project-Class 1.

480 V,.vCC S2CS, Cub. 2CS03 for makeup 22-domineralizer sump pump P966A i

2.

480 Y MCC S2El, Cub. 2E1:S for makeup

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domineralizer sump pump P5668 3.

480 V MCC S2E1, Cub. 2E112 for RHUT, T950C 22-agitator 4.

480 V, MCC S2C1, Cub. 2C110 for regenerant 22-waste transfer pump P6838 5.

480 V, MCC S2C5, Cub. 2C505 for regenerant 22-waste transfer pump P683C 6.

480 V, MCC 52CS, Cub. 2C528 for RHUT, T950C 22-regenerant holdup tank sample pump P941 7.

48G V, MCC S2C2, Cub. 2C232 for the sluicing 22-demineralizer booster pump 8.

480 V, MCC S2C2, Cub. 2C209 for upgraded 22-regenerant transfer pump P683A (relocated l

from Cub. 2C201) 9.

480 V MCC S2C2, Cub. 2C214 for effluent strainer 22-pump P602A

10. 480 V. MCC S2C2, Cub. 2C215 for effluent strainer 22-pump P6028 l
11. 480 Y, MCC 252C, cub. 2C226 for effluent strainer 22-pump P602 I

12.120 V power supply for caustic piping heat tracing 22-i 1

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DESIGN BASIS REPORT E.

Testina Shop hydrostatic testing is required for the sluiceable desineralizer pressure vessels and hoses.

A leak test of the system is required after field installation is complete.

The regenerant waste transfer pumps and the make up domineralizer sump pump shall be tested per the pump specification.

Control panel H4RH shall be shop tested per the panel specification.

III. CALCULATIONS AND DESIGN INFORMATION A.

Desian Information 1.

Make-up Domineralizer Sump and Sump Pumps A new sump will be provided to collect non-radioactive wastes including the make-up domineralizer regenerant wastes and area draina and the sentry cooler drains.

The existing piping from these sources to the polishing domineraliser sump will be capped off.

The sump is sized to limit the pump starts to about three starts per hour with an influent flow of about 150 gpm which yields a sump working volume of about 1200 gallons.

The sump will be constructed of reinforced concrete and lined with 80 mil high density polyethylene (HDPE).

Two sump pumps (one dupiex set) will be provided to transfer the non-contaminated waste water to RHUT T950C.

Each pump is sized for 250 spe flow, equivalent to the maximum make-up dominera11:er cation backwash flow of 144 spm plus 83 gym anion backwash flow plus a 10% design allowance.

Other sump influent streams are 150 spa maximum from five sentry coolers.

Both pumps will operate when the influent flow exceeds 150 spm.

2.

Make-up Domineralizer Regenerant Hold Up Tank (RRUT) T950C The new make-up domineralizer RHUT will have the same capacity, 100,000 gallons, as existing RHUT T950A.

RHUT T9508 has a 200,000 gallon capacity.

The tank will be fabricated of carbon steel, lined with high density polyethylene, and equipped with a side nozzle mounted agitator.

Acid and caustic for tank neutralization will be provided from the existing storage facilities through new piping. The caustic piping will be heat traced to prevent freezing.

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DESIGN BASIS REPORT Piping will be provided to direct RHUT T950C influent to REUT's T950A or T9508 if necessary.

RHUT's T950A and T-9508 will not be transferable to RHUT T950C.

3.

Regenerant Waste Transfer Pumps (P683C)

A new regenerant waste transfer pump will be provided for REUT T9 SOC and will be dedicated to transfer only from this tank to offsite disposal via the retention basins or the bypass line.

A new regenerant waste transfer pump (P6835) will be provided as an in line spare pump to existing pump P683A.

These two pumps will be dedicated to transfer only from REUTs T950A and T9508 to the retention basins via the new effluent strainer provided under ECN A 4954.

The two new pumps will be sized for 1000 spa capacity, to permit transfer of 100,000 gallons from an RHUT in about 1.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> with flow through the effluent strainer.

Pump P683A may require upgrading to overcome the pressure drop across the effluent strainer.

The tank agitator and the two new transfer pumps will be the same as the existing equipment.to optimise meintenance procedures and spare parts inventories for these items.

4.

Control Panel H4RH A new control panel will be provided to replace the existing panel and integrate the new and old controls with the emphasis on human factors and ease of operation.

The new control scheme will include a graphic presentation of-equipment on the panel, a programmable logic control system with remote inputs and outputs, and indication of status for peripheral equipment such as the acid and caustic day tanks.

5.

Sluiceable Demineralizer System A sluiceable demineralizee system consisting of two booster pumps and two demineralizer skids will be provided to process radioactive wastes prior to discharge to the retention basins.

Each demineralizer train will have a 50 gpm capacity which is adequate for processing the flow f rom equipment drains to the condenser pit sump.

The polishing demineralizer system will be operated in the throw away mode during these periods.

RHUTs T950A and T950B will.be utilized for processing radioactive wastes with flow from one RHUT through the sluicing demineralizer to the second RHUT.

'. i : '?

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h i

DESIGN BASIS REPORT The domineralizer skid will be a Duratek system utilizing either their proprietary Durasil ion exchange media or conventional ion ' exchange media or a combination of both.

They system will be a booster pump to overcome the system pressure drop, five exchange pressure vessels, a mechanical filter and shield, interconnecting piping and valves, instrumentation, and control pene1.

8.

Design Calculations calculations will be performed 'to support the design of the sump l

pumps, transfer pumps, sump and foundations, piping and hangers.

j The calculations will be completed prior to final closure of the ECN.

The DBR will be revised to reflect the calculation numbers and titles.

)

l IV.

FAILURE MODES This change does not affect control room instrumentation.

The modifications made under the ECN will not affect previously analyzed plant failure modes. This modification, by segregation clean wastes from i

potentially contaminated wastes provides two benefits.

First, it l

. decreases the total quantity of radioactive discharge, by discharging the clean wastes from its own system.

Second, it increases the concentration of radioactivity in a RHUT by not prediluting with clean wastes. This increased concentration, does increase the total contained activity in the tank, however, increases the efficiency of the domineralizers to remove activity.

The' captured activity at the maximum expected D.F. and through put does not pose a personnel exposure concern, less than 1 mrem /hr at 18 inches.

Even the 200K gallon RHUT with maximum expected concentration does.not create an exposure concern.

Even following the completion of the modification with release concentrations 100 times less than previous concentrations, our limitation on quantity of effluent and offsite exposure remains controlled by 10CFR50 Appendix I of 9.62 mei Cs-137 (No H-3) or 3 mrem exposure.

The decreased volume and concentration ensure our comp 11ance with regulatory guidelines, while operating with an operable OTSG tube leak.

Release procedures will have to be revised to account accurately for the cumulative activity after each discharge.

Technical Specifications 3.15, Radioactive Liquid Effluent Instrumentation and 3.17, Liquid Effluents, are not affected by these revisions.

Figure 11.1-4 Sheet 5 of 5 (ABK248) " Coolant Radwaste System", in USAR Yolume V. Section 11 will be revised to show the new transfer piping from the Demineralized Reactor Coolant Tank to RHUTS T950A and B.

.[.

s V.

SPECIAL MAINTENANCE REOGIREMENTS Equipment seals throughout the Turbine Building must be maintained to minimize the leakage flow rate and oil content in equipment drains to the condenser pit sump.

VI.

SPECIAL OPERATING REQUIREMENTS During operation with failed fuel plus OTSG tube leaks, the polishing demineralizer regeneration will be performed in the throw away mode and the contents of regeneration holdup tanks T950A and T950B will be processed through the sluiceable demineralizer system prior to discharge to the offsite retention ponds.

VII.

VERIFICATION CRITERIA None.

VIII. COMENTS The new RHUT. T950C, will not contain radioactive liquid wastes and discharge from this tank will not be monitored. Technical Specifications 3.15. Radioactive Liquid Effluent Instrumentation and 3.17. Liquid Effluents, will not apply to discharge from RHUT T950C.

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