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Forwards Core Damage Assessment Procedure Station 9918.1, Estimation of Extent of Core Damage. Encl Changes to NUREG-0737,Item II.B.3 Re post-accident Analytical Accuracies Will Be Incorporated Into FSAR Rev
	ML20024C090
Person / Time
Site:	Midland
Issue date:	07/01/1983
From:	Jackie Cook; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Harold Denton; Office of Nuclear Reactor Regulation
Shared Package
ML20024C091	List: ML20024C090; ML20024C094;
References
	RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 23228, NUDOCS 8307120245
	Download: ML20024C090 (7)
	v • d • e

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. .s C011 Sum 8tS l power i James W Cook Vice President - Projects, Engineering and Conssruction General offices: 1945 West Parnal! Road, Jackson, MI 49201 * (517) 788-0453 July 1, 1983 Harold R Denton, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND ENERGY CENTER PROJECT MIDLAND DOCKET NOS 50-329, 50-330 CORE DAMAGE ASSESSMENT PROCEDURE FILE: 0927.4 SERIAL: 23228 ENCLOSURE: TEN COPIES OF THE MIDLAND PLANT CORE DAMAGE ASSESSMENT PROCEDURE Enclosed are ten (10) copies of Consumers Power Company's Midland Plant Core Damage Assessment Procedure for NRC Staff review. In addition, the information regarding post-accident analytical accuracies is attached as an approved FSAR Change Notice. This information will be incorporated into the next revision of the Midland FSAR. In conjunction with the summary of post-accident analytical procedures provided in the NUREG-0737 response section of the FSAR, this letter provides the information necessary to complete the review of Licensing Condition Six of the Midland Plant Safety Evaluation Report.

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CC RJCook, Midland Resident Inspector JGKeppler, Administrator, NRC Region III MAMiller, NRC Ohh9 PDR

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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 23228 Dated July 1, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits the Midland Plant Core Damage Assessment Pro:edure and an approved SAR Change Notice detailing the Post Accident Sampling System Accuracies.

CONSUMERS POWER COMPANY By dy b J Cook, Vice Presic ent Pr ects, Engineering and Construction

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Sworn and subscribed before me this f day o1 O /q / 9/3 .

s n d e< m is Notary Public l Jackson County, Michi an i 1

My Commission Expires _ w//M M//// '

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. QUALITY ASSURANCE PROGRAM

. SAR CHANGE NOUCE

1. 80shdt FSAR JOS NO. 73 A U 2. DISCIPUNE/ COMPANY Mo 3. No. D

4. ORIGINATOR TAM < /M 702sER 5. OAT 8 b 9

6. REFERENCED SECTIONS OF SAR FSAR Cross Reference Index has been checked and affected FSAR pages are attached which reflect appropriate changes.

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7. DESCRIPTION OF CHANGE Is the purpose of this change for anything other than:

Closing an ACRS/SER cpen ite=, correcting an editorial error or providing inf ion already c - 4tted to in

TRC correspondence? e th' If yes, provide furthur justification for the change in Block 9 fDC&O FC) f ACQ Qgr/ f $nmrygg 4 Mj 7fM MLLVMMUCs.

8. REFERENCED SPECIFICATIONS OR DRAWINGS N D h.) V l

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' 9. JUSTIFICATION 400s0 fc5r ACuoaNr St1mn.w > YS tem Mcuvnnuei VCR SRc R Eq u G5t:

10. BECHTEL DISC!PUNE INTERFACE REVIEW: INTERFACING STAFF REVIEW:

C ARCH C 8tANTcSN : AACH C utCs i : C:vIL PCAE : C:VA E NUCLEAA -

l 3 C':NTRCL SYS STRE5s C CONTRCLSYSTEW C Pt.ANTcSN l ELEC CTHER C ELEC C AEL;A81uTY l E MNOCLIM / C GEoTECH STRESS l [. . . . . , , - /,,., .[ ,

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l 11. REVIEWED BY CATE 12. AdtEWECdY DATE 13. REVIEWED BY DATE I IGroup Suotevisert (SAR COORDINATCR) (NUCt. EAR ENGINEERI

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! 14. CONCURRENCE SY DATEl15. APPRCVED SYICPCol DATE iPAOJECT ENGINEEA) l CATE l 16. CCNCURRENCE INSSS SUPoUER) SY l u s casen ers I wo

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e-Responscs to NRC Qusstions-TMI-II Midicnd 1&2

Response

1. The response to NUREG-0737, Item II.B.3 has been revised in .,

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response to this question. In addition, Section 9.3 has been revised to include a description of the post-accident sampling system (PASS). Selected analytical chemistry procedures with documentation demonstrating compliance with licensing conditions will be available on request for NRC audit 4 months prior to exceeding 5% power operation.

2. Sufficient shielding to meet the requirements of GDC-19, assuming a Regulatory Guide 1.4 release, will be provided.

Regulatory Guide 1.4 source terms were chosen because Midland is a PWR. Regulatory Guide 1.3 applies to SWRs.

3. Midland has not committed to implementation of Regulatory Guide 1.97, Rev 2, as noted in Appendix 3A. However, the Midland design for post-accident sampling meets the intent of Regulatory Guide 1.97, Rev 2, as modified and clarified below.

The Midland PASS uses a Sentry Model B sampling panel in conjunction with manual grab sample techniques. Post-accident sample analysis capabilities are provided as follows:

33 For primary coolant and sump samples:

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a. Gross Activity - Sample gross activity will oe analyzed I over the range of 10 u Ci/ml to 10Ci/ml by summation of (

gamma-emitting isotope activities determined during gamma spectrum analysis.

swosse i Here

b. Gamma Spectrum - As noted above, a gamma spectrum isotopic analysis will be provided.

c. Boron Content - Consistent with ALARA, boron a concentration will be initially determined by analyzing a 1,000 to 1 diluted sample. Analysis of this diluted sample will provide a determination of boron content over a range of 500 to 6,000 ppm. The boron analytical technique proposed for this analysis is the generic Drocedure develooed by NUS for Sentry I ipment Corp. 74o.

)mn.vvem. NAtrnr t w a. pon Sc 1m 15%,

kwou It is noted that the 500 to 6,00 ppm range for cetermination of boron content is adequate for verifying maintenance of reactivity control, because 2,270 ppm is the baron content specified for cold shutdown.

Furthermore, this sample analysis is confirmatory and not the primary method of verifying post-accident reactivity control. As noted in Section 7.5, safety grade neutron flux monitoring is provided as the primary and direct indication of reactivity control. In !

Q&R-TMI 5 Revision 41 2/92

Responses to NRC Questions-TMI-II e Midland 102 addition, should the initial boron content analysis indicate boron concentrations below 500 ppm, the PASS has the capability of obtaining an undiluted sample for f analysis below 500 ppm. A decision to analyze an (

undiluted sample for boron content would be made at that time based on ALARA and the need to obtain further information.

d. Chloride content - Consistent with ALARA, chloride i concentration will be initially determined by analyzing 38

, a 1,000 to 1 diluted sample. This analysis is capable

<- of determining chloride content from 10 to 20 ppm and i arves as an early indication that an extreme chloride condition exists.. The chloride analytical technique ,

utilized for this analysis is high pressure lipid

- 0 chro we mura psassur'me tonaopek r h (HPLC)s.zofg, mort /*4 ruw ss su need fo* A een uroov neo withesos the 2~ 14 akoo m s W"W.

[nco unction chloride ana(( sis,nme At M m'de

a dissolved i hydrogen gas analysis utilizing gas chromotography will L 41 be performed to assess the potential for long term

chloride stress corrosion cracking. If this analysis I verifies that hydrogen concentration in the reactor i coolant system (RCS) is greater than 5 cc/kg, then it is reasonable to assume that oxygen will have been scavenged and no further immediate chloride analysis is

, required, because one of the required factors for stress corrosion cracking is not present. Additionally, an undiluted sample will be obtained through the PASS for - /

. later and more accurate confirmation of chloride (

content. This confirmatory analysis will be performed within 2 or 3 weeks dependent on ALARA considerations. 1 If hydrogen concentration in the reactor coolant system j cannot be verified to be significantly above 25 cc/kg.

(i.e., normal operating range) for RCS isolatable 38 i accidents, then it can reasonably be assumed that a substantially smaller percentage core damage has occurred than is considered in the design for post-l.

accident sampling and analysis. In that case, onsite i

chloride analysis of an undiluted sample should be possible consistent with ALARA. Such analysis would l utilize the HPLC analytical technique for determination

, of chloride contant from 0.15 ppm to 20 ppm within the 4 day time frame permitted by NUREG-0737.

e. Dissolved Hydrogen - Consistent with ALARA, a diluted sample will be analyzed for dissolved hydrogen within the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months time constraint of the regulatory guide.

This analysis, utilizing gas chromotography, will be capable of determining dissolved hydrogen over the range of at least 50 to 2,000 cc/kg at atmospheric pressure.

Midland is in the process of determining the lowest practical analytical limit for dissolved hydrogen Q&R-TMI 6 Revision 41 2/92

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Rosponsos to NRC Quostions-TMI-II Midland 1&2 e

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- conceuveazion utilizing samples diluted consistent with 138

- , gne Enang ees WM4, ALARA consideration.

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f. " Dissolved +a2.000 Oxygen - Consistent with the above discussion '

of chloride analysis, dissolved oxygen will not be analy:cd at part of the immediate accident response.

Concern with oxygen in terms of its contribution to chloride stress corrosion cracking can be inferred by determination of hydrogen concentration. As discussed above, if hydrogen concentration is greater than 38 5 cc/kg, it can be reasonably assunad that oxygen is not present in detectable quantities. In the event that dissolved hydrogen cannot be detected at its minimum detectable level, the oxygen concentration will be assumed to equal its saturation concentration at the prevailing sump temperature. In addition, within l

30 days following the accident, an online oxygen monitor will be installed in the system for oxygen analysis if 141 necessary. ;

g. pH - Determination of pH is used in conjunction with !

oxygen and chloride analyses to estimate the potential '

for long-term chloride stress corrosion cracking.

Consistent with ALARA, pH will be initially determined to within one pH number as an indication of whether an extreme pH condition exists. This analysis will be performed within the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months time constraint of the !

regulatory guide. In addition, undiluted samples will be taken for later and more accurate confirmatory analyses consistent with the previous discussion on chloride analysis. 38 For containment air samples:

a. Gamma Spectrum - A grab sample capability is provided for analyzing gamma isotopic spectrum.

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= b. Hydrogen and Oxygen Content - A comsip Delphi analyzer is provided for hydrogen concentration measurement from 0 to 10%. Refer to Subsection 6.2.5.5.3 for more information on the Delphi analyzer. In addition, the capability to take a grab sample through the PASS is available.

4. Electrical components of the PASS, aside from containment isolation valves, will be powered from non-Class lE, diesel backed, ac power. Power to these components will be administratively restored upon loss of offsite power. Power I to the containment isolation valves will be from the ' ,1 l Class 1E, ac power system. In order to sample and analyze within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , access to the PASS panels is required. It has been verified that the PASS liquid sample panel can be i accessed 30 minutes after an accident and that the PASS Q&R-TMI 7 Revision 41 2/82 4

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ML20024C090

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