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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20217F0841999-10-0808 October 1999 Informs That During 466th Meeting of ACRS on 990930-1002, CEOG Proposal to Eliminate PASS from Plant Design & Licensing Bases for CEOG Plants,Were Reviewed.Discussion & Recommendations,Listed ML20217C5311999-10-0808 October 1999 Notification of 991027 Meeting with Representatives of Gpu in Rockville,Md to Discuss Recent Control Rod Surveillance Performance Issues at TMI-1.Proprietary Portions of Meeting Will Be Closed to Public ML20212K8901999-10-0505 October 1999 Notification of 991027 Meeting with Util in Rockville,Md to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TM1-1 ML20216J0151999-09-29029 September 1999 Notification of 991020 Meeting in Forked River,Nj to Discuss Licensee 990922,response to NRC & Other Info Addressing Sale of Portion of Land That Is Part of Plant Site ML20216G3671999-09-10010 September 1999 Forwards CNWRA Program Manager Periodic Rept (Pmpr) for Period 990731-0827 ML20210U7571999-08-20020 August 1999 Forwards Info Received from Gpu Nuclear,Inc on 990820 in Preparation for 990823.Requests Info Be Docketed ML20210C9991999-07-22022 July 1999 Revised Notification of 990813 Meeting with Gpu Nuclear,Inc Rockville,Maryland to Discuss TMI-1 Licensing Action Status. Meeting Date Changed ML20210E9511999-07-12012 July 1999 Notification of 990805 Meeting with Representative of Gpu Nuclear,Inc in Rockville,Md Re Plant,Unit 1 Licensing Action Status ML20212H9621999-06-23023 June 1999 Revised Notification of Meeting with Gpu Nuclear,Inc to Discuss Proposed Mods to RBS Sys Procedures & HPI Cross Connect Lineup.Meeting Rescheduled to 10 A.M. on 990713 ML20195H8521999-06-18018 June 1999 Requests That Encl Questions,Faxed to Gpu Nuclear,Inc on 990616,be Docketed,In Preparation for Forthcoming Conference Call Re TS Change Request 248, Remote Shutdown Sys, ML20195H9911999-06-15015 June 1999 Notification of 990707 Meeting with Util to Discuss Licensee Proposed Mods to Reactor Bldg Spray Procedures & High Pressure Injection Cross Connection Lineup ML20206F2921999-05-0505 May 1999 Forwards Draft Questions Which Were Faxed to Licensee for TMI Unit 1,GPUN on 990505 in Preparation for 990506 Conference Call on TS Change Request 279 ML20206D1291999-04-28028 April 1999 Notification of 990507 Meeting with Gpu Nuclear,Inc in Rockville,Maryland to Discuss Three Mile Island,Unit 1 Licensing Action Status ML20205N3161999-04-0909 April 1999 Notification of Significant Licensee Meeting 99-19 with Util on 990423 to Discuss Emergency Feedwater Flow Discrepancies ML20197G6381998-12-0707 December 1998 Forwards Program Manager Period Rept (Pmpr) for Period 981024-1120 ML20196E2801998-11-30030 November 1998 Discusses Closeout of TAC MA1607 Re Cross Potential for common-cause High Pressure Injection Pump Failure IR 05000289/19983011998-11-0404 November 1998 Forwards NRC Operator Licensing Exam Rept 50-289/98-301 with as Given Written Exam for Tests Administered on 980824-27 at Facility ML20154G3451998-10-0101 October 1998 Rev 2 to Notification of Significant Licensee Meeting 97-73 on 981023 in King of Prussia,Pa to Discuss Actions Taken Re Engineering Corrective Action Performance Assessment Team Findings ML20153D9681998-09-24024 September 1998 Notification of 981006 Meeting W/Gpu Nuclear,Inc in Rockville,Md to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TMI-1 ML20237E8381998-08-28028 August 1998 Notification of 980917 Meeting W/Gpu Nuclear,Inc & Amergen in Rockville,Md to Discuss Sale & Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen ML20237E4591998-08-20020 August 1998 Submits Rev 1 to Notification of Significant Licensee Meeting 98-73 W/Util in Middletown,Pa to Discuss Actions Taken Re Engineering Corrective Action PA Team Findings. Meeting Postponed ML20237C9401998-08-14014 August 1998 Notification of Significant Licensee Meeting 98-73 on 980828 W/Gpu Nuclear,Inc in Middletown,Pa to Discuss Actions Taken Re Engineering C/A Performance Assessment Team Findings ML20247M2191998-05-19019 May 1998 Notification of 980604 Meeting W/Gpu Nuclear Inc in Royalton,Pa to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TMI-1 ML20216B6871998-05-0808 May 1998 Notification of 980527 Meeting W/Representative of Gpu Nuclear,Inc in Rockville,Md to Discuss Licensee 980324 Submittal Re Control Room Habitability at TMI-1 IR 05000289/19980991998-02-26026 February 1998 Notification of Significant Licensee Meeting 98-22 W/Util on 980318 to Discuss SALP for Period Covering 960805-980124,as Documented in SALP Rept 50-289/98-99 IA-98-345, Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 11998-02-0606 February 1998 Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 1 ML20154B7931998-02-0606 February 1998 Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 1 ML20199H6701997-11-20020 November 1997 Notifies of 971212 Meeting W/Gpu in Rockville,Md to Discuss Control Room Habitability at Unit 1 ML20199E7071997-11-14014 November 1997 Revised Notification of 971119 Meeting W/Gpu Nuclear Corp,In Rockville,Md to Discuss Control Room Habitability at TMI-1 Nuclear Facility.Meeting Cancelled Until Further Notice ML20199B3111997-11-0606 November 1997 Notifies of 971119 Meeting W/Gpu in Rockville,Md to Discuss Control Room Habitability ML20212G9531997-11-0505 November 1997 Forwards Gpu SE Re Review of AP600 Shutdowm Ts.Section B.3.9.4 of STS Cites Gpu Nuclear SE 0002000-001 Rev 0,880520 as Ref E Temporary Containment Penetration Closure Devices Equivalent to Valve or Blind Flange ML20216E9871997-09-0808 September 1997 Notification of 970910 Meeting W/Util in Rockville,Md to Discuss Potential Dose Consequences from Postulated Steam Line Break & Postulated Accident Sys Leakage Limits ML20149D8881997-07-11011 July 1997 Notification of Significant Licensee Meeting 97-86 W/Util on 970725 in King of Prussia,Pa to Discuss Apparent Violations Re Failure to Recognize General Emergency Condition During 970305 Exercise ML20140G6231997-06-0505 June 1997 Notification of 970716 Meeting W/Gpun in King of Prussia, Pennsylvania for Presentation & Discussion Re Root Cause Determination for Recent QC Issues Performed by Gpun Per NRC CAL ML20151U4191997-05-23023 May 1997 Discusses Review of Two Addl Concerns Identified in 970407 Memo to Recipient from Special Insp Branch Re Addl Open Items Associated W/Dec 1996 Design Insp Rept 50-289/96-201 ML20148D9851997-05-21021 May 1997 Notification of Significant Licensee Meeting 97-57 W/Util on 970528 to Discuss Formal Exit Meeting for Licensee Remedial Emergency Preparedness Exercise on 970513 & Licensee Discussion Re NRC CAL ML20141E5381997-05-15015 May 1997 Notification of 970530 Meeting W/Representatives of Gpu Nuclear Corp in Rockville,Md to Discuss Status of Licensing Activities Associated W/Plant,Unit 1 ML20138D3161997-04-21021 April 1997 Notification of Significant Licensee Meeting 97-47 W/Util on 970430 to Discuss Root Cause Analysis of 970305 Emergency Preparedness Drill Weaknesses ML20140D5251997-04-18018 April 1997 Notification of 970502 Meeting W/Util in Rockville,Md to Discuss Schedules & Resolution of Issues Relating to Thermo-Lag Fire Barriers ML20135F8801997-03-0404 March 1997 Notification of Significant Licensee Meeting 97-27 W/Util on 970317 to Discuss Emergency Preparedness Insp Exit Meeting ML20138M3111997-02-20020 February 1997 Notification of 970306 Meeting W/Gpu in Rockville,Md to Discuss Three Mile Island,Unit 1 Reactor Pressure Vessel pressure-temp Limit Curves ML20147D8391997-02-12012 February 1997 Notification of 970220 Meeting W/Util Representatives in Rockville,Md to Discuss Status of Licensing Activities Associated W/Plant,Unit 1 Facility ML20133Q3031997-01-16016 January 1997 Notification of Significant Licensee Meeting 97-08 W/Util on 970131 in Middletown,Pa Re Safety Sys Functional Insp Exit Meeting ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20129K3731996-11-21021 November 1996 Notification of 961126 Meeting W/Gpun in North Bethesda,Md to Discuss TMI-1 SG Issues ML20135B0871996-11-15015 November 1996 Notification of Significant Licensee Meeting 96-118 W/Util on 961122 to Discuss Plant Motor Operated Valve Testing Program self-assessment ML20129K2561996-11-0505 November 1996 Notification of Significant Licensee Meeting 96-109 W/Listed Attendees on 961202-03 in Philadelphia,Pa to Provide Training,Resolve Interagency Exercise Scheduling Conflicts & Discuss Current Issues in Emergency Preparedness ML20136E3011996-10-31031 October 1996 Forwards Schedule for Activities at Plant for Next Few Months ML20134E9191996-10-29029 October 1996 Forwards Rationale for Inital Plants Selected for Design Insps & for Plants Considered for Second Quarter FY97 Design Insps ML20128G1661996-10-0303 October 1996 Summarizes 960924 Meeting W/Gpu Nuclear Corp in Rockville,Md Re Preliminary Responses to Staff RAI Concerning Request to Change EALs for TMI-1.List of Participants & Copy of Preliminary Response to RAI Encl 1999-09-29
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20217C5311999-10-0808 October 1999 Notification of 991027 Meeting with Representatives of Gpu in Rockville,Md to Discuss Recent Control Rod Surveillance Performance Issues at TMI-1.Proprietary Portions of Meeting Will Be Closed to Public ML20217F0841999-10-0808 October 1999 Informs That During 466th Meeting of ACRS on 990930-1002, CEOG Proposal to Eliminate PASS from Plant Design & Licensing Bases for CEOG Plants,Were Reviewed.Discussion & Recommendations,Listed ML20212K8901999-10-0505 October 1999 Notification of 991027 Meeting with Util in Rockville,Md to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TM1-1 ML20216J0151999-09-29029 September 1999 Notification of 991020 Meeting in Forked River,Nj to Discuss Licensee 990922,response to NRC & Other Info Addressing Sale of Portion of Land That Is Part of Plant Site ML20216G3671999-09-10010 September 1999 Forwards CNWRA Program Manager Periodic Rept (Pmpr) for Period 990731-0827 ML20210U7571999-08-20020 August 1999 Forwards Info Received from Gpu Nuclear,Inc on 990820 in Preparation for 990823.Requests Info Be Docketed ML20210C9991999-07-22022 July 1999 Revised Notification of 990813 Meeting with Gpu Nuclear,Inc Rockville,Maryland to Discuss TMI-1 Licensing Action Status. Meeting Date Changed ML20210E9511999-07-12012 July 1999 Notification of 990805 Meeting with Representative of Gpu Nuclear,Inc in Rockville,Md Re Plant,Unit 1 Licensing Action Status ML20212H9621999-06-23023 June 1999 Revised Notification of Meeting with Gpu Nuclear,Inc to Discuss Proposed Mods to RBS Sys Procedures & HPI Cross Connect Lineup.Meeting Rescheduled to 10 A.M. on 990713 ML20195H8521999-06-18018 June 1999 Requests That Encl Questions,Faxed to Gpu Nuclear,Inc on 990616,be Docketed,In Preparation for Forthcoming Conference Call Re TS Change Request 248, Remote Shutdown Sys, ML20195H9911999-06-15015 June 1999 Notification of 990707 Meeting with Util to Discuss Licensee Proposed Mods to Reactor Bldg Spray Procedures & High Pressure Injection Cross Connection Lineup ML20206F2921999-05-0505 May 1999 Forwards Draft Questions Which Were Faxed to Licensee for TMI Unit 1,GPUN on 990505 in Preparation for 990506 Conference Call on TS Change Request 279 ML20206D1291999-04-28028 April 1999 Notification of 990507 Meeting with Gpu Nuclear,Inc in Rockville,Maryland to Discuss Three Mile Island,Unit 1 Licensing Action Status ML20205N3161999-04-0909 April 1999 Notification of Significant Licensee Meeting 99-19 with Util on 990423 to Discuss Emergency Feedwater Flow Discrepancies ML20203E0321999-02-11011 February 1999 Staff Requirements Memo Re 990211 Affirmation Session in Rockville,Md (Open to Public Attendance) Re Secys 99-044 & 99-045 ML20197G6381998-12-0707 December 1998 Forwards Program Manager Period Rept (Pmpr) for Period 981024-1120 ML20196E2801998-11-30030 November 1998 Discusses Closeout of TAC MA1607 Re Cross Potential for common-cause High Pressure Injection Pump Failure IR 05000289/19983011998-11-0404 November 1998 Forwards NRC Operator Licensing Exam Rept 50-289/98-301 with as Given Written Exam for Tests Administered on 980824-27 at Facility ML20154G3451998-10-0101 October 1998 Rev 2 to Notification of Significant Licensee Meeting 97-73 on 981023 in King of Prussia,Pa to Discuss Actions Taken Re Engineering Corrective Action Performance Assessment Team Findings ML20153D9681998-09-24024 September 1998 Notification of 981006 Meeting W/Gpu Nuclear,Inc in Rockville,Md to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TMI-1 ML20237E8381998-08-28028 August 1998 Notification of 980917 Meeting W/Gpu Nuclear,Inc & Amergen in Rockville,Md to Discuss Sale & Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen ML20237E4591998-08-20020 August 1998 Submits Rev 1 to Notification of Significant Licensee Meeting 98-73 W/Util in Middletown,Pa to Discuss Actions Taken Re Engineering Corrective Action PA Team Findings. Meeting Postponed ML20237C9401998-08-14014 August 1998 Notification of Significant Licensee Meeting 98-73 on 980828 W/Gpu Nuclear,Inc in Middletown,Pa to Discuss Actions Taken Re Engineering C/A Performance Assessment Team Findings ML20248H7001998-05-20020 May 1998 Staff Requirements Memo Re SECY-98-071,exemption to 10CFR72.102(f)(1) Seismic Design Requirement for TMI-2 ISFSI ML20247M2191998-05-19019 May 1998 Notification of 980604 Meeting W/Gpu Nuclear Inc in Royalton,Pa to Discuss Status of Licensing Actions Proposed & Currently Under Review by NRC for TMI-1 ML20216B6871998-05-0808 May 1998 Notification of 980527 Meeting W/Representative of Gpu Nuclear,Inc in Rockville,Md to Discuss Licensee 980324 Submittal Re Control Room Habitability at TMI-1 IR 05000289/19980991998-02-26026 February 1998 Notification of Significant Licensee Meeting 98-22 W/Util on 980318 to Discuss SALP for Period Covering 960805-980124,as Documented in SALP Rept 50-289/98-99 ML20154B7931998-02-0606 February 1998 Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 1 IA-98-345, Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 11998-02-0606 February 1998 Discusses Licensing Basis for Letdown Line Break Outside Containment for Plant,Unit 1 ML20199H6701997-11-20020 November 1997 Notifies of 971212 Meeting W/Gpu in Rockville,Md to Discuss Control Room Habitability at Unit 1 ML20199E7071997-11-14014 November 1997 Revised Notification of 971119 Meeting W/Gpu Nuclear Corp,In Rockville,Md to Discuss Control Room Habitability at TMI-1 Nuclear Facility.Meeting Cancelled Until Further Notice ML20199B3111997-11-0606 November 1997 Notifies of 971119 Meeting W/Gpu in Rockville,Md to Discuss Control Room Habitability ML20212G9531997-11-0505 November 1997 Forwards Gpu SE Re Review of AP600 Shutdowm Ts.Section B.3.9.4 of STS Cites Gpu Nuclear SE 0002000-001 Rev 0,880520 as Ref E Temporary Containment Penetration Closure Devices Equivalent to Valve or Blind Flange ML20216E9871997-09-0808 September 1997 Notification of 970910 Meeting W/Util in Rockville,Md to Discuss Potential Dose Consequences from Postulated Steam Line Break & Postulated Accident Sys Leakage Limits ML20149D8881997-07-11011 July 1997 Notification of Significant Licensee Meeting 97-86 W/Util on 970725 in King of Prussia,Pa to Discuss Apparent Violations Re Failure to Recognize General Emergency Condition During 970305 Exercise ML20140G6231997-06-0505 June 1997 Notification of 970716 Meeting W/Gpun in King of Prussia, Pennsylvania for Presentation & Discussion Re Root Cause Determination for Recent QC Issues Performed by Gpun Per NRC CAL ML20151U4191997-05-23023 May 1997 Discusses Review of Two Addl Concerns Identified in 970407 Memo to Recipient from Special Insp Branch Re Addl Open Items Associated W/Dec 1996 Design Insp Rept 50-289/96-201 ML20148D9851997-05-21021 May 1997 Notification of Significant Licensee Meeting 97-57 W/Util on 970528 to Discuss Formal Exit Meeting for Licensee Remedial Emergency Preparedness Exercise on 970513 & Licensee Discussion Re NRC CAL ML20141E5381997-05-15015 May 1997 Notification of 970530 Meeting W/Representatives of Gpu Nuclear Corp in Rockville,Md to Discuss Status of Licensing Activities Associated W/Plant,Unit 1 ML20138D3161997-04-21021 April 1997 Notification of Significant Licensee Meeting 97-47 W/Util on 970430 to Discuss Root Cause Analysis of 970305 Emergency Preparedness Drill Weaknesses ML20140D5251997-04-18018 April 1997 Notification of 970502 Meeting W/Util in Rockville,Md to Discuss Schedules & Resolution of Issues Relating to Thermo-Lag Fire Barriers ML20135F8801997-03-0404 March 1997 Notification of Significant Licensee Meeting 97-27 W/Util on 970317 to Discuss Emergency Preparedness Insp Exit Meeting ML20138M3111997-02-20020 February 1997 Notification of 970306 Meeting W/Gpu in Rockville,Md to Discuss Three Mile Island,Unit 1 Reactor Pressure Vessel pressure-temp Limit Curves ML20147D8391997-02-12012 February 1997 Notification of 970220 Meeting W/Util Representatives in Rockville,Md to Discuss Status of Licensing Activities Associated W/Plant,Unit 1 Facility ML20133Q3031997-01-16016 January 1997 Notification of Significant Licensee Meeting 97-08 W/Util on 970131 in Middletown,Pa Re Safety Sys Functional Insp Exit Meeting ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20129K3731996-11-21021 November 1996 Notification of 961126 Meeting W/Gpun in North Bethesda,Md to Discuss TMI-1 SG Issues ML20135B0871996-11-15015 November 1996 Notification of Significant Licensee Meeting 96-118 W/Util on 961122 to Discuss Plant Motor Operated Valve Testing Program self-assessment ML20129K2561996-11-0505 November 1996 Notification of Significant Licensee Meeting 96-109 W/Listed Attendees on 961202-03 in Philadelphia,Pa to Provide Training,Resolve Interagency Exercise Scheduling Conflicts & Discuss Current Issues in Emergency Preparedness ML20136E3011996-10-31031 October 1996 Forwards Schedule for Activities at Plant for Next Few Months 1999-09-29
[Table view] |
Text
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p h Jul. 2 2 1981 e p u h # #,h gd1
.f ',.h S KHORANDUM FOR: William P. Camill, Chief -
6' Ju . W 1981 * 'S .
Effluent Treatment Systems Branch, 051 .." ,'qi 0 2
, guian /
FROMt. Charles A. Willis, Leader, Sectier. B Effluent Treatment Systens Branch, 0$1 f /
Jacques 5. Boeg11, Section 8
[ Effluent Treatment Systems Branch, OSI SUBJECT TECH $PEC ON CONTROL OF EXPtfS!VE CAS MIXTURES IN THE WA$TE GAS $YSTEM AT THI-1 In attempting to update (to current requirenents) the_ Tech Spec of THI-1, a problem was encountered in the control of explosive gas mixtures in the wast?
gas system (WGS). Af ter some effort, a position was found which was accept-able to the utility and which seems to provide as much protection against a l H2 -- 02 explosion as would the provisions of the model RETS (NUREG-0472).
The bases for the T'11-1 Tech Spec are reported here because they nav help with the solution of related problems,elsewhere.
Insufficient H2 -- 02 Monitoring The basic problem at TN!-1 was insufficient monitoring equipment. Their nonitoring system consists of a single analyzer for H2 and another for Op.
Samples are taken sequentially from 10 locations as indicated in Figure I.
While each point is monitored every-20 ninutes, the monitoring is not actually continuous. Neither is it dual and redundant, so it does not meet m
the requirements of the SRP 11-3. Thus, the model RETS requirements do not fit the situation and become quite burdensome.
Other Safety Features Incorporated in the Desinn
- We conclude that the system could be deemed to meet the intent of the NRC
< requirements only if the design includes safety features which are not re-
. quired. Thus, considerable effort was expended to gain a detailed under-standing of.the system and its operation.
A principal unrequired safety feature is that both 112 and 02 are controlled.
Ch 1
- Dilution by N2 is provided to keep the concentrations below 31112 and 0.1% 02 .
Thus, neither a failure which allows excess 112 nor a failure which allows g)!/
- excess oxygen will result in a combustable mixture (Fiqure 2). }/
Furthemore, special provisions are made to limit the probability of oxygen $8 ' 1. g' entering the system. First, the compressors are equipped with water seals and operated under a N2 blanket so a leak would not bring air into the g . T,/
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-o W1111am P. Caus111- 22 g system. Second . the system is maintained at a potitive pressure,15.5 to l 16.4 psia so, ag,ain, a leak would not mean air inleakage. Finally, the oxygen l content of waste gases is limiteds.even the gas from the miscellaneous waste ;
L evaporator and the miscellaneous waste tank cover gas are held to 0.1% 02 ' l
- consequently, a high concentration of oxygen is highly unlikely. l The relatively large volume of the waste gas system also contributes-to j i= i
-of safety.
11,050 - Thi5 ft each.Even volume with is all provided 3 bleedbytanks the three 'f::11*-ofreactor coolant liquid, 3000bleed f t of tanks,3 ,
- gas space rereins. The header, pipingI Misc. Waste Tank gas space, and waste {;
gas delay tank provide another- jo00 ft . The three waste gas decay tanks
! each have a capacity of 1150 ft et 85 psig (7800 scf). The large volume !
' limits the rate at which concentrations can change. ;
Evidently _ the system did contain unrequired features so the task became one- l of finding-approoriste Tech Specs. ;
Limit Both H -- 2 and 02 Concentrations t
p The first step was to limit both constituents with the following liniting ;
i conditten for operation * - !
'The. concentrations in the waste gas system shall be limited l to less than or equal to 21 oxygen by volume and 41 hydrogen ;
by vol me." ,
A principal value of this requirement is that it ensures retention of the important safety feature now provided by procedures (which are subject to l
- - change without notice). Also it provides an acceptable point of departure t for safety analysis. No single failure produces unacceptable conditions.
This requirement also has the virtue of being essentially ' free". It only !
requires something less than is already being done. .
Action Required for Inoperable Monitoring Equipment ;
The model RETS requirements for action in response to loss of monitoring !
capability are relatively severe, including shutdown if the equipment is
- 1 ' corresponds to NUREG-0472 LC0 3.11.2.5.
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V1111am P. Canmill not returned to operation in a timely r.anner. The NRC position (SRP 11-3) if that the probability of a forted shutdown should be ninimited by providing
- dua) monitors but many OR$, including THI-1, do not have dual monitors.
t.icensees find these requirments objectionable and contend that more appro-priate actions can provide equivalent Safety.
For this specific system it was concluded that less onerous requirenents could
. provide equivalent safety. First, it wcs recognized that only 2 precautionary measures are available if monitoring capablitty is lost, vir.:
- 1. grab samples, and
- 2. dilution Second, since the waste gas system encounters very dif ferent conditions in the dif ferent operational phases (startup, steady t,peration and shutdown), it is reasonable to establish dif ferent action requirements for the different con-ditions.
During nomal operations additions to the waste gas systens are relatively small.
t.etdown to the bleed tarts will be the principal source and even r.;ar the end of core 11fe bleed will not exceed 4000 gpd. At most3 this could add only 21.4 SCF/ day of 112 With minimum gas *.'olume (9000 f t ) and this noxinum rate of hydrogen introduction, it would take 4.4 days to increase the average hydrogen concentration one percent. Since a 1% increase would bring the con-centration to 4% or less, no potential hazard is created. Thus the action iten* requires taking and analyzing greib samples every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and, if necessary, diluting to 3% 112 and 0.1% 02 '
This assures that flamable concentrations will not be reacted durin;l nomal operations even if the monitoring system is inoperable.
During startup the bleed rate is nuch greater than during non al operation, pririartly because of deboration. With the nsxinun biced rate (45 qpn) and a mintrum gas volume,112 concentration can be increased it in only 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.
Accordingly, the action item requires sariple analysis prior to startup and every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during startup wtth dilution requirec any time the concentra-tions exceed 3% 112 or 2% 02 '
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- This provides safety during startup, even with the H2 and 02 monitors increrable.
The most dif ficult operation for H2 control is degassing (af ter shutdown).
The purpose of this operation is to remove gases,' including hydrogen, from the coolant. Therefore, a large quantity of hydrogen is deliberately added to the waste gas system. The coolant can contain up to 500 $CF of dissolved hydrogen and there can be another 400 $CF in ttM makeup tank. Furthennore, much of the hydrogen from the enkeu,s tank is cdded to the waste gas system quite soon af ter the isolation valve is opened. To assure safety of this operation, before de-gassing, a grab sempie is analyzed and (* necessary, dilution is provided to ensure thdt the concentrations are less than 1% 112 and 2% 20 . Then during degassing at least 4 tires as much nitrogen as waste gas is added to the system.
Of course, this degree of' dilution may nos keep the H concentration below the Tech Spec limit, but it does ensure a mixture of H2 e 2 and air cannot be flamable if the 112 and the air comprise only 20% of he volume. To ensure
- t. hat the hydrogen concentration does not remain high and assure that dilution is ef fective, grab samples are to be analyzed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
These requirements er.wre safety during degassing, even if the monitoring syster.1 is inoperable.
Finally, it is recognized that the monitoring equipment should not be out of service for an extended period. In principle, reliance on e.dministrative controls is not preferred practice. In the model P. CTS 'this principal is reflected in an action" requirement that the plant be shut down if the monitors are not made operable in 30 days. Since a shutdown is likely to cost a million dollars or more, the shutdown requirement provides a strong incehtive to repair the instruments (guickly. On the other hand, licensees contend that (1) a forced shutdown is an excessive penalty for inability tn repair an instrteent that is not safety related, and (2) shutdown is not an appropriate response to loss of waste gas system monitoring instruments l because shutdown tends to increase the addition of waste pas to the system.
Therefore, an al'. rnate requirement was imposed. The THI-1 Vice President (or his designate) must call the l*C and explain the delay any time the weste gas H2 -- 02 monitor is out of service for more than 7 days.
l Thus a provision is included to pronote timely repair of the instrumentation.
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William P. Gamill Conclusion For the specific waste gas systees of TM!-1 the new Tech Spec provision !
(Enclosure 1) provides the same degree of protection against waste gas ;
explosions as do the provisions of the mJdel RETS. Therefore, these Tech Specs are adjudged to neet the intent of standard NRC requirements in this area.
Original signed by:
Charles A. Willis, Leader, Section B Ef fluent Treatment Systems Branch O! vision of Systems Integration CHg!bal signed by Jacques S. Boegli, Section R Ef fluent Treatment Systems Dranch !
Division of Systems Integration Enclosure As noted cct R. Hattson '
W. Kreger .
I F. Congel '
O. Ottanni J. Buchanan R. Bangart CTSB Staff DISidlBUTION:
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, Central File ETSB Reading File ETSB Subject File 5.4 CAWillis JSBoegli i
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0 100 - Flaneable Limits !
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- Assumed petonable 10 90 tiaits .
20 -go 30 70 40 / c 60 .
50 50 0xygen,v/o 60, - 40 70 t 30 btr Mtut 20
- - . 10 90 100 -
80 90 100 40 50 60 70 0 10 20 30 11ydrogen, v/o 9
FICURE 2. FIAMMABILITT LIMITS OF ;IYDROGEN-0XYCEN-HITROGEN HIXTURES
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TM!-1 TECH $PEC REQUIREMENTS FOR CONTROL Of EXPLOSIVE GAS MIXTL'RES 3.22.2.5 The concentration in the waste gas holdup system shall be limited to less than or equal to 25 0xygen by volume and 45 Hydrogen by vol ume.
APPLICABILITY AT ALL TIMES.
ACTION At With the concentration in the waste gas holdup system greater than ,
25 0xygen by volume or 4% Hydrogen by volume, immediately minimize additions of waste g:ses to the system and rdduce the concentra- I tions to less than the aforementioned values within one hour.
ACTION 30: With the number of channels OPERABLE less than that required by the Minimum Channels Operable requirement (a)* (1) Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, take and analyre an initial grab sample. ,
Grab samples shall be taken every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> until the monitor is declared operable. ,
(ii) If the sample indicates greater than 25 0xygen or 35 Hydrogen, within one hour begin to add Nitrogen to reduce ..
the concentration to less than .1% 0xygen or 31 flydrogen.
-(iii) Prior to Startup if the Hydrogen concentration is greater than 31, Nitt ogen shall be added to reduce the Hydrogen concentration to 3%. During Startup operations, a grab sample shall be taken and analyzed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. .
'If the hydrogen monitor is operational, hydrogen montor results may be used .
rather than grab sample analysis for hydrogen. Alternately, if the oxygen !
monitor is operational, oxygen monitor results may be used rather than grab i J
sample analysis for oxygen.
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(iv) Prior to degas operations, a grab sample shall be taken and analyzed. If the Hydrogen concentration is greater than ll, Nitrogen shall be added t'o reduce the Hydrogen concentrations to less than it. During the degas operation, ,
a grab sample shall be taken and analyzed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
6 During degas Operat.fon add four times as much N2 as waste gas to the system (waste gas addition inay be estimated).
, (b) If the channel is not OPERABLE within seven days a telephone call i
will be made by the Vice President of TH!-1 (or his designate) to ,
i the Director of Region 1 Of fice of Inspection and Enforcement (or . .
his designate) describing the reas9ns for the delay and the cor.
rective actions being taken. A written report documenting reasons l
for the delay and corrective actions taken will be forwarded within 1 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the telephone notification.
NOTE: These requirements corre; pond to LCO 3.11.2.5 and to Action 39 in the model RETS (NUREG-0472).
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