ML20213A414

Rev 1 to TVA Employee Concerns Special Program Sequoyah Element Rept 230.5(B), HVAC Design,Airborne Radioactivity in Cdwe Bldg

ML20213A414
Person / Time
Site:	Sequoyah
Issue date:	01/20/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20213A334	List: ML20213A333 ML20213A353 ML20213A371 ML20213A384 ML20213A401 ML20213A414 ML20213A423 ML20213A435 ML20213A447 ML20213A451 ML20213A453 ML20213A457 ML20213A461
References
230.5(B), 230.5(B)-R01, 230.5(B)-R1, NUDOCS 8702030266
Download: ML20213A414 (15)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(8)

SPECIAL PROGRAM REPORT TYPE:

SEQUOYAH ELEMENT REVISION NUMBER:

1 TITLE:

HVAC DESIGN Airborne Radioactivity in CDWE Building PAGE 1 0F 14 i

REASON FOR REVISION:

1.

Incorporation of Senior Review Panel (SRP) and Technical Assistance Staff (TAS) comments of 12/05/86, and compliance with report format revisions 3 of 12/10/86, adding Chronology to Section 9, and Section 10, Corrective Action.

PREPARATION PREPARED BY:

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(B)

SPECIAL PROGRAM REVISION NUMBER:

1 PAGE 2 0F 14 1.

CHARACTERIZATION OF ISSUE (S):

Concern:

Issues:

RII-85-A-0007 a.

The vent gas cooler of the condensate "An anonymous alleger stated that demineralizer waste evaporator (CDWE) the vent condenser at the condenser in the CDWE building vents Condensate Demineralizer Building noncondensible gases into the duct (CDWE)ventsnoncondensible leading to the auxiliary building, gases to the duct in the CDWE building where it is discharged b.

During auxiliary building isolation, to the Auxiliary Building (Aux.

noncondensible gases build up in the Bldg). During an Aux Bldg CDWE building and iodine concentra-isolation the exhaust dampers tions may be unacceptable because isola-isolate the CDWE building from tion dampers could remain unnoticed the Aux. Bldg and noncondensible in a closed position for long periods, gases can build up in the CDWE Bldg. At times, the iodine c.

TVA should take immediate corrective

. centration in the CDWE Bldg action to preclude unnecessary are apparently somewhat [high, exposure of personnel to airborne which renders the CDWEB]

radioactivity and minimize airborne inaccessible and [the exhaust radioactivity in the CDWE building.

dampers] may go unnoticed in the closed position for long periods d.

The corrective actions should be of time, documented and a followup program performed and documented.

TVA should evaluate this situ-ation and if in fact the problem currently exists, take immediate action to preclude unnecessary exposure of personnel to air-borne radioactivity.

In addition, TVA simuld take actions to minimize the airborne problems in the CDWE Bldg.

This may include such actions as providing additional filtered i

ventilation, better access and control of the dampers.

The corrective actions simuld be documented and an expanded followup program performed to determine that the corrective actions solved the problem. The 4

l followup program should be documented.

I l

01580 - 12/29/86 i

l t

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(B)

SPECIAL PROGRAM REVISION NUMBER:

1 PAGE 3 0F 14 Concern (cont'd):

This allegation is spelcific to Sequoyah; however, there are generic implications for other TVA nuclear plants such as Watts Bar."

2.

HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES N0 X Identified by Not Applicable Date Not Applicable Documentation Identifiers:

3.

DOCUMENT N05., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

No specific document or tag numbers were stated in concern.

The condensatedemineralizerwasteevaporator(CDWE)issharedby l

Sequoyah Units 1 and 2 and located in its own building.

4 INTERVIEW FILES REVIEWED:

The ECTG working file for concern RII-85-A-0007 was reviewed.

No additional information on this concern was contained in the file.

5.

DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

6.

WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A.

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01580 - 12/29/86 1

w TVA EMPLOYEE CONCERNS REPORT NUMBER:

230.5 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 14 7.

LIST REQUESTS FOR'INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu.T0 ELEMENT.

See Appendix A.

8.

EVALUATION PROCESS:

a,'

Traced the path of potential iodine and other noncondensibles

~

from their origins to the condensate demineralizer waste evaporator building (CDWEB) atmosphere.

Evaluated frequency of simultaneous occurrence of incidents leading to the condition of concern.

b.

Estimated radioactivity in noncondensibles from the CDWE vent gas cooler.

Investigated protective measures for personnel in the CDWEB.

c.

9.

DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronology:

i 12/79:

ECN SQN2744 initiates rerouting of CDWE vent lines through the CDWEB roof instead of into the WGS 11/83:

TVA memo Green to Sprouse transmits completed SQ-DCR-L-1941 for the vent line rerouting 1?/83:

TVA memo Standifer to Wadewitz directs another rerouting of the CDWE vent lines into the CDWEB ventilation duct instead of through the CDWEB roof 01 /8 6:

S01-77.183, Rev. 42 cautions against operating the CDWE while an ABI is in effect 02/86:

50I-30.5D, Rev. 27 cautions operators to reset the ABI signal within 15 minutes or shut down the CDWE 07/86:

Concern received by TVA 015PD - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(B)

SPECIAL PROGRAM REVISION NUMBER:

1 PAGE 5 0F 14 Discussion:

g I

The CDWE is located in a separate building (CDWEB) adjacent to the southeast corner of the auxiliary building. The 30 gpm capacity evaporator package was provided by Horton Process Design (HPD) Inc.

and is a forced-circulation, vertical tube heater type.

It was primarily intended for concentrating the neutralized spent regenerating liquids from the condensate polishing demineralizer system (CPDS). The CPDS was designed for full-flow treatment of the secondary (turbine steam) loop condensate.

The CDWE was also designed as backup to the 2 gpm capacity waste evaporator and the 15 gpm capacity auxiliary waste evaporator for processing floor and tritiated drain wastes.

Air induced by the CDWEB supply fan through a duct from the auxiliary building is used for ventilation. This ventilation air is supplied to areas of low potential for radioactive contamination and migrates to areas of progressively higher potential for contamination. The CDWEB exhaust fan returns air from the area with highest contamination potential through a duct to the exhaust l

system in the auxiliary building. Double isolation dampers in the ventilation ducts to and from the auxiliary building close when the auxiliary building stack monitor detects high radiation.

This auxiliary building isolation (ABI) may occur as a result of fuel handling accidents or spills and leaks within the auxiliary building. A loss of coolant accident (LOCA) also results in an ABI as part of the secondary containment enclosure. The double isolation dampers have a manual override switch, allowing opening or closing. Fire dampers are installed in the CDWEB-to-auxiliary building wall penetrations. Two separate air conditioning systems are p'rovided in the CDWEB for heat removal, one serving rooms of low potential for contamination, and one serving rooms of high potential for contamination. The CDWEB has a monitored door to the outside for emergency exit.

Per HPD piping and instrument diagrams 101 through 106 (App. A, 5.f), there are five equipment vent lines originating from the CDWE package: a 6-inch heater relief valve discharge line and a 4-inch blowdown tank rupture disc relief lire exhausting through the roof; one 2-inch vent line each from the tilowdown and the bottoms tank; and a 1-inch line from the vent gas cooler. The latter three tie together and were originally routed to the waste gas system (WGS) in the auxiliary building.

01580 - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 6 0F 14 A TVA memo from D. R. Patterson to R. M. Pierce ( App. A, 5.v),

dated 11/13/79, initiated rerouting of the three combined CDWE equipment vents through the CDWEB roof to atmosphere.

The reason for rerouting was that the vent gas cooler noncondensible mass flow (45 lb/hr) exceeded the WGS capacity. More importantly, the WGS processes hydrogen-rich gases from the Chemical and Volume Control System (CVCS) holdup vessels and adding gases containing oxygen is specifically prohibited.

A letter from HPD to TVA ( App. A, 5.s), dated 10/23/86 corrected I

the noncondensible mass flow to 4.5 lb/hr, down from 45 lb/hr.

The recommendation of the above memo was incorporated into the design by ECN SQN 2744 ( App. A, 5.b), and is reflected on Drawing 47W560-23 R3, Section G23 - G23 ( App. A. 5.g).

This change created the potential for an unmonitored release point.

l A TVA memo from J. C. Standifer to G. Wadewitz ( App. A, 5.h), dated I

l?/22/83, replied to an earlier memo from G. Wadewitz to J. C.

Standifer (App. A, 5.1), which quotes an HPD Inc. design i

representative expressing concern over a remote possibility of contaminants exhausting through the vent gas cooler vent line under abnormal evaporator operation. Standifer added that in view of the recent decision to process radwaste through the CDWE, the vent gas cooler line should be rerouted again, this time into the CDWEB ventilation duct returning to the auxiliary building. The TVA memo

( App. A, 5.h) further committed to issuing an ECN for routing the vent gas cooler vent line into the ventilation duct. While such an ECN could not be located, a TVA memo from H. J. Creen to M. N.

Sprouse ( App. A, 5.j), dated 11/09/83, transmitted field-completed I

SQ-DCR-L-1941, ( App. A, 5.k), which documented rerouting of the vent gas cooler and slurry tank vent lines to the ventilation duct.

(See Appendix B for a schematic depiction of the CDWEB.)

This routing was verified by a site inspection ( App. A, 5.x).

This l

change removed the potential for uraanitorcd release from the CDWEB, but created the pot:ntial for backup of radioactive contaminants in the CDWEB during periods of an ABI.

[

Per Table 12.1.4-1 of the SNP FSAR, ( App. A, 5.a) there is no area radiation monitor located in the CDWEB.

Detailed Design Criteria No. SQN-DC-V-22.0, ( App. A, 5.e) specifies a liquid radwaste disposal system modification to replace the installed waste and auxiliary waste evaporators with byperfiltration units (HFU).

The HFUs will be designed for i

processing radwaste and neutralized CPDS waste. Further 4

concentration of these wastes is intended by the CDWE.

0158D - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(B)

SPECIAL PROGRAM REVISION Nt;MBER:

1 PAGE 7 0F 14 The HFU and CDWE are not safety-related and their functions are not l

required for tost-accident operation.

Table 11.2.2-2 of the SNP FSAR ( App. A, 5.a) shows the radionuclide I

discharge rates from the waste evaporator and auxiliary waste evaporator package vents (including iodines) under normal operation as negligible. These rates correspond to the CDWE package vent rates when processing radwaste.

Per telephone conversation with TVA, (App. A, 6.h; 10/31/86), a CDWE vent activity release rate l

study is presently in progress to confirm this.

The waste evaporator areas in the auxiliary building are monitored for area radiation levels. Since the CDWE is now routinely processing radwaste, the same criteria for monitoring could apply to the CDWEB as well.

Per Nuclear Operating Experience Inc. Reports 352 and 353 (App. A, 5.p), frequent ABIs occurred at Sequoyah from January through April 1984 due to normal maintenance operations and spurious signals.

ABI is a safety-related function and control room annunciation is provided.

TVA System Operating Instructions S01-77.183 (App. A, 5.t) requires

[

shutting down the CDWE upon an ABI, and verifying isolation damper opening prior to restarting the CDWE. TVA System Operating Instructions 50I-30.5D (App. A, 5.u) requires resetting of the l

auxiliary building isolation signal within 15 minutes of an ABI or shutting down the CDWE.

Findings:

I a.

ECNs and DCRs confirm routing of. the vent gas cooler and other CDWE package vents into the ventilation duct leading to l

the auxiliary building. The evaporator vendor drawings and l

TVA drawings have not been revised to reflect these changes.

b.

There is a remote potential for backup of radioactive contaminants in the vent duct during periods of auxiliary building isolation and simultaneous abnormal evaporator operation.

The expected contaminant level is negligible during normal evaporator operation.

01580 - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(8)

SPECIAL PROGRAM REVISION NUMBER:

1 PAGE 8 0F 14 Past history indicates that erroneous isolation of the c.

auxiliat}y building and associated automatic closing of the isolation dampers in the ventilation ducts can be expected.

The potential for radioactive exposure to personnel because of this is negligible since the CDWE System Operating Instructions (501) include references to a S0I for recovery from ABI, which limits the time period of CDWE operation with concurrent ABI. Manual override switches are provided, allowing opening of the isolation dampers for exhausting CDWEB air.

d.

Since no immediate corrective actions are necessary, no documentation is required.

If the current TVA review of the CDWE vent activity rates suggests adding an area or continuous air monitor to the CDWEB, it will be documented under the as-low-as-reasonably-achievable (ALARA) program.

l

==

Conclusion:==

The concern is not valid with respect to unacceptable iodine concentration in the CDWEB.

The necessary simultaneous occurrence l'

of the abnormal conditions causing the vent gas to back up into the CDWEB and the normally low potential for radioactivity in the vent gas, coupled with the system operating instructions for CDWE shutdown and recovery from an ABI, make hazardous exposure to l

radioactive iodine very unlikely.

The concern is valid in that there is no continuous monitoring for potential airborne radioactivity in the CDWEB.

However, a clear need for such a monitor could not be established because of the negligible amount of contamination normally expected. No design change is required prior to restart. However, the remote potential l

hazard to personnel may be inconsistent with ALARA guidelines. The need for monitoring on a continuing basis'could be established by temporarily installing an air monitoring system. Administrative l

procedures do exist for shut down of the CDWE and remote manual l

opening of the auxiliary building isolation dampers for exhausting of airborne contamination.

The design drawings of the CDWE package require updating to match the ECNs, DCRs, and as-built configuration.

l 01580 - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 14

10. CORRECTIVE ACTION:

A TVA letter (App. A, 5.w) transmitted the corrective action plan (CAP) which will consist of an ECN by the Mechanical Engineering Branch (MEB) to revise the applicable drawings reflecting as-built routing of the CDWE vent lines per SQ-DCR-L-1941. This is to include the flow sheet from HPD (App. A, 5.f) correcting the vent gas cooler noncondensible flow per HPD Letter (App. A, 5.s).

ALARA concerns regarding airborne contamination in the CDWEB will be evaluated and documented by the Nuclear Engineering Branch (NEB).

l 01580 - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(8)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 10 0F 14 APPENDIX A I

5.

DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

Updated SNP FSAR Sections 1.2, 6.2, 9.4.2, 9.4.9, 10.4.6, a.

11.2,11.4,12.1.3, and 12.1.4 and Amendments 2 and 3 b.

TVA General Design Criteria No. SQN-DC-V-3.2, R1, "The Classification of Heating, Ventilating, and Air-Conditioning Systems" TVA General Design Criteria No. SQN-DC-V-13.9.3, R0, c.

" Auxiliary Building Ventilation and Cooling System 30/31-AB" d.

TVA General Design Criteria No. SQN-DC-V-13.9.4, R0,

" Auxiliary Building Secondary Containment Ventilation System - System 30-SC" TVA General Design Criteria No. SQN-DC-V-22.0, R2, " Liquid e.

Radwaste Disposal System Modification" f.

Horton Process Design (HPD) Inc. Drawings (TVA Contract l

1. 77K64-821338):

101, R901 ' Hourly Process Flowsheet CDWE SNP 102, R3 P&ID, CDWE SNP 103, R906 P&ID, CDWE SNP 104, R902 P&ID, CDWE SNP 105, R4 P&ID, CDWE SNP 106, R902 P&ID and Process Flowsheet for CDWE for Blowdown t

Tank and Distillate Test System SNP 300, R902 General Arrangement Plans CDWE SNP 301, R901

. General Arrangement Elevations CDWE SNP 302, R902 General Arrar.gement Elevations CDWE SNP 407, R908 Small Piping COWE SNP g.

TVA Drawings:

47W803-7, R9 Mechanical, Flow Diagram, Waste Disposal System 47W560-23, R3 Mechanical Waste Disposal System 47W560-22, R7 Mechanical, Waste Disposal System h.

TVA memo from J. C. Standifer to G. Wadewitz, (MEB 831222 010), (12/22/83) 1.

TVA memo from G. Wadewitz to J. C. Standifer, (WBN 830928 905), (09/28/83) 01580 - 12/29/86

l TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5 (B)

SPECIAL PROGRAM

~

REVISION NUMBER: 1 PAGE 11 0F 14 APPENDIX A (continued)

I j.

TVA memo from H. J. Green to M. N. Sprouse, (DES 831117 001),

(11/09/83) k.

SQ-DCR-L-1941, (06/08/83) 1.

SQN ECN 2744 (SWP 791117 518), (12/11/79)

SQN FCR 3532 (B25 850610 516), (06/03/85) m.

n.

SQN SQWP 10N256R19, Map showing CDWEB SQN HPD CDWE Instruction Manual Sections 1.1.5 through 2.5.5 o.

Nuclear Operating Experience Inc. Reports published by the S. M.

p.

Stoller Corp., Volume PWR-2,Section XIV, " Buildings and Containment," B. Miscellaneous, Articles 352 and 353 (Sequoyah) q.

NUREG/CR-0142, ORNL/NUREG-42, "The Use of Evaporation to Treat Radioactive Liquids in Light-Water-Cooled Nuclear Reactor Power Plants," by H. W. Godbee and A. H. Kibbey TVA General Design Guidelines No. DG-M18.7.1, " Radiation Protection r.

( ALARA) Design Guidelines," (11/20/81)

Letter from A. M. Washburn (HPD) to C. Chandley (TVA), (10/23/86),

s.

contract 77K65-821228, CDHE noncondensible flowrate t.

SQNP System Operating Instruction 501-77.lB3-Unit 0, Rev. 42,

" Condensate Demineralizer Waste Evaporator" SQNP System Operating Instruction S01-30.50 - Units 1 and 2, u.

Rev. 27, " Recovery From Auxiliary Building Isolation" TVA memo from D. R. Patterson to R. M. Pierce (MEB 791113 122),

v.

(11/13/79)

Letter from Gi R. McNutt, TVA, to G. L. Parkinson, Bechtel, TCAB-018 w.

(12/05/86) TVA ECEP-SQN Restart Program - Corrective Action Plan (CAP)

Memo with attached sketch from E. Croft, Bechtel SQN to W. Blumer, x.

Bechtel, (01/03/87) ole 8D - 12/29/86

TVA EMPLOYEE CONCERNS REPORT NUMBER:

230.5 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 12 0F 14 APPENDIX A (continued) l 6.

WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

a.

SNP FSAR Sections 9.4.9,11.4, and 12.2.4, (04/14/83),

through Anendment 3, (04/86) b.

10 CFR 50, Appendix A, GCC 63 and 64, (02/10/71) l c.

10 CFR 20, Section 20.103 7.

LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu TO ELEMENT.

(

Request for Infomation (RFI) SQN #555, (09/10/86) a.

b.

Telephone conversation from W. Blumer, Bechtel, to H.

I Mahlman, TVA, (09/19/86), IOM #465 Telephone conversation from W. Blumer, Bechtel, to R. H.

l c.

Anderson / Bill Brown, TVA Sequoyah, (09/23/86), IOM #467 d.

Telephone conversation from W. Blumer, Bechtel, to L. Grasser TVA Sequoyah, (09/30/86), IOM #466 l

Telephone conversation from H. A. Mahlman/T. Gode, TVA, to W.

e.

Blumer, Bechtel, (10/01/86), IOM #468 l

f.

Telephone conversation from H. A. Mahlman, TVA, to W. Blumer, Bechtel, (10/03/86), IOM #464

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g.

Telephone conversation from W. Blumer, Bechtel, to W. Brown, TVA Sequoyah, (10/07/86), ICM #463

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h.

Telephone conversation from H. A. Mahlman, TVA to W. Blumer, Bechtel, (10/31/86), IOM #368 l

1.

Telephone conversation from W. Blumer, Bechtel, to H. A.

Mahlman/G. McNutt/R. Gibbs, TVA, (12/17/86), IGN #461 l

j.

Telephone conversation from D. Drouhard, TVA to W. Blumer, Bechtel, (09/26/86), IOM #491 k.

Telephone conversation from W. Blumer, Bechtel, to E. Crof t, Bechtel SQN, (12/22/86), IOM #471 015PD - 12/29/86 J

TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 13 0F 14 APPENDIX B g

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.5(B)

-SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 14 CATO LIST l

The following CATDs identify and provide corrective actions for the findings included in this report:

230.05(B) SQN 01 (11/26/86) 230.05(B) SQN 02 (11/26/86)

I l

l 01580 - 12/29/86 i

l f

11 122 PAGE TENNESSEE VALLEY AUTHORITY RUN TIME - 12:57:19 S

REFERENCE

- ECPSI20J-ECPSI21C OFFICE OF NUCLEAR POWER RUN DATE - 12/02/86 FREQUENCY

- REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

OllP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 25005 AIRBORNE RADI0 ACTIVITY IN CDHE 9

KEYHORD A S

GENERIC KEYNORD B H

APPL QTC/NSRS P

KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S

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SR AN ANONYMOUS ALLEGER STATED THAT THE RII-85-A-0007 EN 23005 N SQN NNYY VENT CONDENSER AT THE C0tIDENSATE DE REPORT MINERALIZER BUILDING (CDITE) VENTS NO

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N-CONDENSIBLE GASES TO THE DUCT IN T

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HE CDNE BUILDING HHERE IT IS DISCHAR GED TO THE AUXILLARY BUILDING ( AUX B

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BUILDING FROM THE AUX BUILDING AND NON-CONDENSIBLE GASES CAN BUILD UP I N THE CDHE BUILDING. AT TIMES, THE

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