BYRON 2020-0026, CY-BY-170-301, Revision 15, Offsite Dose Calculation Manual. (Part 3 of 3)

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CY-BY-170-301, Revision 15, Offsite Dose Calculation Manual. (Part 3 of 3)
ML20113E865
Person / Time
Site: Byron  Constellation icon.png
Issue date: 02/28/2019
From:
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20113E860 List:
References
BYRON 2020-0026 CY-BY-170-301, Rev 15
Download: ML20113E865 (19)
v • d • e


Text

Byron Station ODCM Revision 15 Change Determination CY*AA-170-3100 Station:-=B"--'-'-ro=n'"---------------------

ODCM Revision No: -'-'15=-_ _ _ _D,etermination Identifier: A - Administrative Changes

_x_ Yes _ No

1. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR20.1301?

Explain:

This ODCM change will maintain the radioactive effluent control required by 10CFR20.1301, Dose Limits for Individual Members of the Public, which is to ensure total effective dose equivalent to individual members of the public from licensed operation does not exceed 0.1 rem.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes affect the radioactive effluent control required by 10CFR20.1301.

_x_.Yes _No

2. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR20.1302?

Explain:

This ODCM change will maintain the level of control required in 10CFR20. The requirement of 10CFR20.1302 is to provide "surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10CFR20.1301."

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes affect the radioactive effluent control required by 10CFR20.1302.

Page I of 17

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:""'B""'"'"ro=n~-------------------

ODCM Revision No: ..,_15=--_ _ _ _ Determination Identifier: A - Administrative Changes

_x_ Yes

3. Does the ODCM change maintain the level of radioactive effluent control required by - No 40CFR190 and 10CFR72.104?

Explain:

This ODCM change will not reduce the control required by 40CFR190. The controls required by 40CFR190 and 10CFR72.104 include limiting the annual dose equivalent of any member of the public to less than 25 mrem whole body, 75 mrem thyroid, and 25 mrem to any organ as the result of activities from the uranium fuel cycle, including direct radiation from ISFSI.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these changes affect the ability to maintain radioactive effluent and direct radiation controls required by 40CFR190 and 10CFR72.104.

_x_ Yes No

4. Does the ODCM change maintain the level of radioactive effluent control required by -

10CFR50.36a?

Explain:

This ODCM change does not affect the level of control previously established in the ODCM required by 10CFR50.36a. The basic requirement of 10CFR50.36a is to keep releases and the resultant dose to the public as low as reasonably achievable (ALARA). This ODCM change will not reduce the station's ability to keep releases of radioactive materials to unrestricted areas as low as reasonably achievable, as required by 10CFR50.36a.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes affect the radioactive effluent control required by 10CFR50.36a.

_x_ Yes _No

5. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR50 Appendix I?

Explain:

10CFR50 Appendix I states that liquid effluents from each reactor each year shall not expose any individual to more than 3 mrem to the total body or 10 mrem to any critical organ. Gaseous releases of particulates and iodines with half-lives >8 days shall not expose any individual organ to more than 15 mrem/year. Noble gases shall not expose any individual total body to more than 500 mrem/year, skin to more than 3000 mrem/year, gamma dose to 10 mrad/year, and beta dose to 20 mrad/year.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes affect the radioactive effluent control required by 10CFR50 A~~endix I.

-* _x_ Yes - No

6. Does the ODCM change maintain the accuracy or reliability of effluent, dose, or setpoint calculations?

Explain:

The accuracy and reliabilitt of effluent, d5>se, and setooint calculations will not be affected bv Page 2 of 17

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:~B"""'yr~o=n~ - - - - - - - - - - - - - - * - - - - - -

ODCM Revision No: _,15 _= -_ _ _ _ Determination Identifier: A- Administrative Changes this ODCM change. Effluent and setpoint calculations will continue to be performed using the established ODCM methodology.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes affect the accuracy or reliability of effluent, dose, or setpoint calculations.

7. Does the ODCM change maintain the accuracy of radioactive effluent control required by

_x_Yes

- No the FSAR?

Explain:

This ODCM change will maintain the accuracy of the radioactive effluent control required by the Byron/Braidwood UFSAR. The B/8 UFSAR Table 11.5-6, Radiological Analysis Summary of Gaseous Effluent Samples, includes typical sampling frequency, type of analysis, sensitivity, and purpose for effluent radiation monitors. No UFSAR described effluent samples or monitors are affected by this change.

Determination A changes are administrative in nature. The changes include adding clarification to REMP air sampler location table references, adding "continued" to table titles, darkening of flow diagram lines, and correction of typos.

None of these administrative changes alfect the accuracy of radioactive effluent control required by_!!_le FSAR.:

Page3ofl7

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:~ B " " " " " " r o = n ~ - - - - - - - - - - - - - - - - - - - -

ODCM Revision No: "'15 ""'e.__ __ Determination Identifier: B - SGBD Overboard Modification. EC #624333

_x_Yes _No

1. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR20.1301?

Explain:

This ODCM change will maintain the radioactive effluent control required by 1OCFA20. 1301 , Dose Limits for Individual Members of the Public, which is to ensure total effective dose equivalent to individual members of the public from licensed operation does not exceed 0.1rem.

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the GP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations.

This ODCM change does not affect any radioactive effluent control required by 1OCFA20.1301 . The change is only being made to the ODCM drawing to reflect the new flow eath, which continues to be through a monitored effluent ~athway.

-- _x_ Yes

2. Does the ODCM change maintain the level of radioactive effluent control required by - - No 10CFR20 .1302?

Explain:

This ODCM change will maintain the level of control requ ired in 1OCFA20. The requirement of 10CFR20.1302 is to provide "surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10CFA20.1301 ."

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the GP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks . Therefore, this modification has no impact to offsite dose calculations.

The change to ODCM Figure 2-1 does not affect any radioactive effluent controls required by 10CFR20.1302. The change is only being made to the ODCM drawing to reflect the new flow path, which continues to be throuqh a monitored effluent pathway.

_x_ Yes

3. Does the ODCM change maintain the level of radioactive effluent control required by - No 40CFA190 and 10CFR72.104?

Explain:

This ODCM change will not reduce the control required by 40CFR190. The controls required by 40CFR190 and 10CFR72.104 include limiting the annual dose equivalent of any member of the public to less than 25 mrem whole body, 75 mrem thyroid, and 25 mrem to any organ as the result of activities from the uranium fuel cycle, including direct radiation from ISFSI.

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the CP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium . However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations.

Page 4 of 17

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:....::B::..,..:.;ro,..n_,___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

ODCM Revision No: ~15~_ _ _ _ Determination Identifier: B - SGBD Overboard Modification, EC #624333 This ODCM revision does not affect radioactive effluent or direct radiation controls and therefore maintains the level of radioactive effluent control required by 40CFR190 and 10CFR 72.104. The change is only being made to the ODCM drawing to re11ect the new flow path, which continues to be throuah a monitored effluent oathway.

_x_Yes _No

4. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR50.36a?

Explain:

The basic requirement of 10CFR50.36a is to keep releases and the resultant dose to the public as low as reasonably achievable (ALARA) .

This EC installed piping to allow SGBD water at a total 11ow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the CP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations .

This ODCM revision does not reduce the station's ability to keep releases of radioactive materials to unrestricted areas as low as reasonably achievable, and therefore does not affect the level of control previously established in the ODCM required by 10CFR50.36a.

The change is only being made to the ODCM drawing to reflect the new flow path, which continues to be throu qh a monitored effluent pathway.

Pugc5ot"17

Byron Station ODCM Revision 15 Change Determination CY*AA-170-3100 Station:-=B:.,.,..ro=n"----------------------

ODCM Revision No: -"15=--_ _ _ _ Determination Identifier: B - SGBD Overboard Modification. EC #624333

5. Does the ODCM change maintain the level of radioactive effluent control required by

_x_ Yes

- No 10CFR50 Appendix I?

Explain:

10CFR50 Appendix I states that liquid effluents from each reactor each year shall not expose any individual to more than 3 mrem to the total body or 10 mrem to any critical organ. Gaseous releases of particulates and iodines with half-lives >8 days shall not expose any individual organ to more than 15 mrem/year. Noble gases shall not expose any individual total body to more than 500 mrem/year, skin to more than 3000 mrem/year, gamma dose to 10 mrad/year, and beta dose to 20 mrad/year.

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the CP trench to extend the lite of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations.

This ODCM revision does not affect the amount of liquid and gaseous effluent releases required to maintain the level of radioactive effluent control required by 1OCFASO Appendix I. The change is only being made to the ODCM drawing to reflect the new flow path, which continues to be throuoh a monitored effluent oathwav.

6. Does the ODCM change maintain the accuracy or reliability of effluent, dose, or setpoint

_x_Yes

- No calculations?

Explain:

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the CP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations.

The accuracy and reliability of effluent, dose, and setpoint calculations will not be affected by this ODCM change. The change is only being made to the ODCM drawing to reflect the new flow path, which continues to be throuoh a monitored effluent oathwav.

7. Does the ODCM change maintain the accuracy of radioactive effluent control required by

_x_ Yes

- No the FSAR?

Explain:

This ODCM change will maintain the accuracy of the radioactive effluent control required by the Byron/Braidwood UFSAR. The 8/B UFSAR Section 11 .2 describes liquid radwaste management systems and concentrations and doses expected from liquid releases. The 8/8 UFSAR Section 11.5 describes process and effluent radiological monitoring and sampling systems.

This EC installed piping to allow SGBD water at a total flow rate of up to 100 gpm per unit to bypass the SGBD demineralizers and be routed directly to the CP trench to extend the life of the SGBD demineralizers, allow overall reduction in SGBD flow, and recover thermal output. The EC increases the amount of water being discharged, which normally contains tritium. However, the amount of tritium present in secondary process water when discharged is negligible compared to the amount of tritium being discharged via liquid release tanks. Therefore, this modification has no impact to offsite dose calculations .

The revision to ODCM Figure 2-1 does not affect the ability to maintain the accuracy of radioactive effluent control required by the FSAR. The chanqe is only beinq made to the Page 6 of 17

Byron Station ODCM Revision 15 Change Determination CV-AA-170-3100 Station:-=B==ro:.:n.,___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

ODCM Revision No: ~1~ 5 _ _ _ _ Determination Identifier: 8- SGBD Overboard Modification, EC #624333 ODCM drawing to reflect the new flow path, which continues to be through a monitored effluent athwa . ----*--------------------- - - - - - - - - - - - -

---T--1

] ***---- __ L___

Page 7 of 17

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:..,,B~ro....,n..,___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

ODCM Revision No: ~15~_ _ _ _ Determination Identifier: C- Bypass of U1/U2 SJAE offgas filter units. EC

  1. 402667/402668)

_x_ Yes - No

1. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR20.1301?

Explain:

This ODCM change will maintain the radioactive effluent control required by 10CFR20.1301, Dose Limits for Individual Members of the Public, which is to ensure total effective dose equivalent to individual members of the public from licensed operation does not exceed 0.1rem.

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s). and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However. the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such. 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a high rad alarm has been eliminated. Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. OOCM figures were updated to reflect the new plant configuration in previous ODCM revisions. however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers . Since no changes are being made to the way dose calculations are being performed. the resultant doses are unchanged, and the radioactive effluent control requ ired by 10CFR20.1301 is maintained.

_x_ Yes

2. Does the ODCM change maintain the level of radioactive effluent control required by - No 10CFR20 .1302?

Explain:

This ODCM change will maintain the level of control required in 10CFR20. The requirement of 10CFR20 .1302 is to provide "surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10CFR20.1301."

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s). and installed a block to restrain the valve in the open position. Originally. the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a high rad alarm has been eliminated. Enaineerina calcs associated with these modifications concluded that the Page 8 of 17

Byron Station ODCM Revision 15 Change Determination CV-AA-170-3100 Station:~B"-'"'"ro=n~-------------------

ODCM Revision No: .._15=--_ _ _ _ Determination Identifier: C - Bypass of U1/U2 SJAE offqas filter units, EC

  1. 402667/402668) permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to provide surveys of radiations levels and maintains the level of control of radioactive materials r~g~_

ire

_d- '-

b.__

y _1"'"

0C - '--

F'--

R_2 _

0 ._ _ _ ___________,_ _ __.____ ,

Page 9 of 17

Byron Station ODCM Revision 15 Change Determination CY*AA-170-3100 Station:~B'"'y~ro=n~ - - - - - - - - - - - - - - - - - - - -

ODCM Revision No: ~ 15

~ _ _ _ _Determination Identifier: C - Bypass of U1/U2 SJAE offgas filter units. EC

  1. 402667/402668) x Yes - No
3. Does the ODCM change maintain the level of rad ioactive effluent control required by 40CFR190 and 10CFR72.104?

Explain:

This ODCM change will not reduce the control required by 40CFR190. The controls required by 40CFR190 and 10CFR72.104 include limiting the annual dose equivalent of any member of the public to less than 25 mrem whole body, 75 mrem thyroid, and 25 mrem to any organ as the result of activities from the uranium fuel cycle, including direction radiation from ISFSI.

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s), and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a high rad alarm has been eliminated. Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to maintain the radioactive effluent or direct radiation controls re quired by 40CFR190 and 10CFR 72.104.

4. Does the ODCM change maintain the level of radioactive effluent control required by

_x_ Yes

- No 10CFR50.36a?

Explain:

This ODCM change does not affect the level of control previously established in the ODCM required by 10CFR50.36a. The basic requirement of 10CFR50.36a is to keep releases and the resultant dose to the public as low as reasonably achievable (ALARA). This ODCM change will not reduce the station's ability to keep releases of radioactive materials to unrestricted areas as low as reasonably achievable, as required by 10CFR50.36a.

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s), and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a hiah rad alarm has been Page 10 of 17

Byron Station ODCM Revision 15 Change Determination CY-AA-170-3100 Station:~B~ro=n~-------------------

ODCM Revision No: "'"15:......_ _ _ _Determination Identifier: C - Bypass of U1/U2 SJAE offgas filter units, EC

  1. 402667/402668)

- - -eliminated.

Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to maintain releases of radioactivity to the unrestricted area ALARA.

Page I I of 17

Byron Station ODCM Revision 15 Change Determination CV*AA-170-3100 Station:-B-ro=n~--------------------

ODCM Revision No: "'""15_ _ _ _ _ Determination Identifier: C- Bypass of U1/U2 SJAE offgas filter units, EC

  1. 402667/402668)

_x_ Yes _No

5. Does the ODCM change maintain the level of radioactive effluent control required by 10CFR50 Appendix I?

Explain:

10CFR50 Appendix I states that liquid effluents from each reactor each year shall not expose any individual to more than 3 mrem to the total body or 10 mrem to any critical organ. Gaseous releases of particulates and iodines with half-lives >8 days shall not expose any individual organ to more than 15 mrem/year. Noble gases shall not expose any individual total body to more than 500 mrem/year, skin to more than 3000 mrem/year, gamma dose to 10 mrad/year. and beta dose to 20 mrad/year.

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s), and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a high rad alarm has been eliminated. Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged and this change does not affect the ability to meet Appendix I requirements.

_x_Yes _No

6. Does the ODCM change maintain the accuracy or reliability of effluent, dose, or setpoint calculations?

Explain:

The accuracy and reliability of effluent and dose calculations will not be reduced. They will be unaffected or increased as a result of these changes. Setpoint calculations will not be affected.

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s), and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a hiqh rad alarm has been Page 12 of 17

Byron Station ODCM Revision 15 Change Determination CY*AA-170-3100 Station:....B " " ' " ' " r o = n ~ - - - - - - - - - - - - - - - - - - -

ODCM Revision No: -'-'15"--_ _ _ _D,etermination Identifier: C - Bypass of U1/U2 SJAE offgas filter units. EC

  1. 402667/402668) eliminated. Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not reduce the accuracy or reliabilitv of effluent, dose, or setooint calculations.

_x_ Yes _No

7. Does the ODCM change maintain the accuracy of radioactive effluent control required by the FSAR?

Explain:

ECs 402667/402668 removed the existing actuators from 1/20G035, Unit 1/2 Off Gas (OG)

System Vent Stack Isolation Valve(s), and installed a block to restrain the valve in the open position. Originally, the system was designed to route flow through the charcoal filter unit OG01 S upon sensing radiation in the steam jet air ejector (SJAE) exhaust. However, the filter unit was isolated early on in plant operation due to problems with wetting the charcoal.

That left the flow path through 1/20G035 as the only vent path for the exhaust of the vacuum hogging pumps and SJAEs. As such, 1/20G035 represented a significant single point vulnerability (SPV) in that it would cause a loss of condenser vacuum potentially leading to a reduction in reactor power if it were to spuriously close. Removal of the actuator and installation of a block ensured that the valve remains in the open position at all times, but the ability to filter radioiodines in the event of a high rad alarm has been eliminated. Engineering calcs associated with these modifications concluded that the permanent bypass of the filter units does not result in a significant increase in radioactive materials or dose to the public. ODCM figures were updated to reflect the new plant configuration in previous ODCM revisions, however, the ODCM Section 1.24 Ventilation Exhaust Treatment System definition was not updated as recommended in EC 402667.

The definition is being updated to include the words "as required" when describing how ventilation exhaust treatment systems are designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers. ODCM Figure 2-1 is being updated to reflect the removal of the filtration capability of the offgas filter unit. Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the accuracy of radioactive effluent control required by the FSAR. --

Page 13 of 17

Byron Station ODCM Revision 15 Change Determination CY*AA-170-3100 Station:~B~ro~n~-------------------

ODCM Revision No: ~15~_ _ _ _ Determination Identifier: 0- FSAR Footnote Update

_x_Yes

1. Does the ODGM change maintain the level of radioactive effluent control required - No by 1OGFR20.1301?

Explain:

This ODGM change will maintain the radioactive effluent control required by 10GFR20.1301, Dose Limits for Individual Members of the Public, which is to ensure total effective dose equivalent to individual members of the public from licensed operation does not exceed 0.1 rem.

Per the ODGM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODGM contains a footnote that states "Licensees may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and the radioactive effluent control required by 10CFR20.1301 is maintained.

_x_ Yes

2. Does the ODCM change maintain the level of radioactive effluent control required - No by 10CFR20. 1302?

Explain:

This ODCM change will maintain the level of control required in 10CFR20. The requirement of 10CFR20.1302 is to provide "surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10CFR20.1301."

Per the ODCM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODCM contains a footnote that states "Licensees may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to provide surveys of radiations levels and maintains the level of control of radioactive materials required by 10CFR20.

_x_ Yes

3. Does the ODCM change maintain the level of radioactive effluent control required - No by40CFR190 and 10CFR72.104?

Explain:

This ODCM change will not reduce the control required by 40CFR190. The controls required by 40CFR190 and 10CFR72.104 include limiting the annual dose equivalent of any member of the public to less than 25 mrem whole body, 75 mrem thyroid, and 25 mrem to any organ as the result of activities from the uranium fuel cycle, including direction radiation from ISFSI.

Per the ODCM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRC in the Annual Radioactive Effluent Release Report. The ODCM contains a footnote that states "Licensees mav choose to submit the information called for in this standard as oart of the Page 14 of 17

Byron Station ODCM Revision 15 Change Determination CY*AA*170-3100 Station:_B~ro~n~--------------------

ODCM Revision No: ~ 15~ _ _ _ _Determination Identifier: D - FSAR Footnote Update annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to maintain the radioactive effluent or direct radiation controls required by 40CFR190 and 10CFR 72.104.

Page 15ofl7

Byron Station ODCM Revision 15 Change Determ ination CV-AA-170-3100 Station:~B"-'-'-ro=n~------- - - - - - - - - - - - -

ODCM Revision No: ..,_15=---_ _ _ _ Determination Identifier: D- FSAR Footnote Update

_x_Yes

4. Does the ODGM change maintain the level of radioactive effluent control requ ired - No by 1OGFR50.36a?

Explain:

This ODGM change does not affect the level of control previously established in the ODGM required by 10GFR50.36a. The basic requirement of 10CFR50.36a is to keep releases and the resultant dose to the public as low as reasonably achievable (ALARA). This ODCM change will not reduce the station's ability to keep releases of radioactive materials to unrestricted areas as low as reasonably achievable, as required by 10CFR50.36a.

Per the ODGM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODGM contains a footnote that states "Licensees may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the ability to maintain releases of radioactivity to the unrestricted area ALARA.

_x_ Yes

5. Does the ODCM change maintain the level of radioactive effluent control required - No by 10CFR50 Appendix I?

Explain:

10CFR50 Appendix I states that liquid effluents from each reactor each year shall not expose any individual to more than 3 mrem to the total body or 10 mrem to any critical organ. Gaseous releases of particulates and iodines with half-lives >8 days shall not expose any individual organ to more than 15 mrem/year. Noble gases shall not expose any individual total body to more than 500 mrem/year, skin to more than 3000 mrem/year, gamma dose to 10 mrad/year, and beta dose to 20 mrad/year.

Per the ODGM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODGM contains a footnote that states "Licensees may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged and this change does not affect the ability to meet Appendix I requirements.

_x_ Yes - No

6. Does the ODGM change maintain the accuracy or reliability of effluent, dose, or setpoint calculations?

Explain :

The accuracy and reliability of effluent and dose calculations will not be reduced.

They will be unaffected or increased as a result of these changes. Setpoint calculations will not be affected . I Per the ODGM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODGM contains a footnote that states "Licensees Page 16 or 17

Byron Station ODCM Revision 15 Change Determination CV-AA-170-3100 Station:-=B=--y.__ro"'"'n-'----- - - - -- - - - - - - - - - - - - -

ODCM Revision No: -'-'15,,___ _ _ _ Determination Identifier: D - FSAR Footnote Update may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not reduce the accuracy or reliability of effluent, dose, or setpoint calculations.

_x_ Yes - No

7. Does the ODCM change maintain the accuracy of radioactive effluent control required by the FSAR?

Explain:

Per the ODCM, major changes to Liquid and Gaseous Radwaste Treatment Systems are required to be reported to the NRG in the Annual Radioactive Effluent Release Report. The ODCM contains a footnote that states "Licensees may choose to submit the information called for in this standard as part of the annual FSAR update." Station FSAR updates are now being performed biannually, so the footnote is being revised to reflect the biannual FSAR updates.

Since no changes are being made to the way dose calculations are being performed, the resultant doses are unchanged, and this change does not affect the accuracy of radioactive effluent control required by the FSAR.

Date: _ _ _ l_-_f_-_(_r Date: d-f'-/ 9 Page 17 of 17

Byron Station ODCM Revision 15 Change Summary Matrix Administrative Changes - Determination A Technical Changes (SGBD Overboard Modification, EC #624333) - Determination B Technical Changes (Bypass of U1/U2 SJAE offgas filter units, EC #402667/402668) - Determination C Technical Changes (FSAR Footnote Update) - Determination D

- - - ..--- - - - - - ~ - - - - _ _ _ M____ _ - - - - - - - - - - - - -

Item (old) Rev. (new) Rev. Oeterm Description of Change No. page No. page No. nation ldentifi er

1. 9 of 1BB 9 of 188 C
  • Added "as required" to the Ventilation Exhaust Section Section Treatment System definition when describing that 1.24 1.24 exhaust gases are passed through charcoal adsorbers.
2. 25 of 188 25 of 188 D
  • Changed footnote that describes FSAR update

,_ ___ Section 5.4 Section 5.4 frequency from annual to biannual

3. 42 of 188 42 of 188 C
4. 42 of 188 42 of 188 B
5. 47 of 188 47 of 188 B
  • Changed first sentence of Condensate Polisher Section Section Sump description from "The condensate polisher 2.1.3.1 2.1 .3.1 sump receives wastewater from the condensate polisher system, which is normally non-radioactive but potentially contaminated" to The condensate polisher sump receives wastewater and secondary process water from the condensate polisher system ,

which is normally non-radioactive but potentially contaminated ."

6. 53 of 188 53 of 188 C
  • Added "as required" to the Ventilation Exhaust Section Section Treatment System description when describing that 2.4.2.1 2.4.2.1 exhaust gases are passed through charcoal adsorbers.
7. 63 of 188 63 of 188 B
  • Revised figure to add SGBD flow path that bypasses Figure 2-2 Figure 2-2 SGBD demineralizers and discharges water to CP sump

- - --+-- - - - - - - - - - - - - - - - - - - - - - - - -

8. 63 of 188 63 of 188 A
  • Darkened some lines in flow diagram for consistency Figure 2-2 Figure 2-2 Page 1 of 2

Byron Station ODCM Revision 15 Change Summary Matrix Administrative Changes - Determination A Technical Changes (SGBD Overboard Modification, EC #624333)- Determination B Technical Changes (Bypass of U1/U2 SJAE offgas filter units, EC #402667/402668) - Determination C Technical Changes (FSAR Footnote Update) - Determination D

9. 173 of 188 173 of 188 A
  • Changed Section 2.c "Indicators-Other" title to Table 6-1 Table 6-1 "Indicators" and definition from "At each airborne location listed in Section 1 :" to "At all airborne indicator locations listed in Section 1" and remov ed BY-01, BY-04, BY-06, BY-21
10. 174 of 188 174 of 188 A
  • Removed "Indicators-Other (cont'd)" and BY-22, BY-Table 6-1 Table 6-1 23, BY-24
  • Changed Section 2.d "Control" definition from "A t each airborne location listed in Section 1:" to "At the control airborne location listed in Section 1" and removed BY-08
11. 185 of 188 185 of 188 A
  • Added the following note to table title:

Table 6-2 Table 6-2 "Dosimeters are also located at each air samplin g station."

12. 186 of 188 186 of 188 A
  • Added "(continued)" to Table 6-2 title Table 6-2 Table 6-2
13. 187 of 188 187 of 188 A
  • Added parentheses to "continued" in Table 6-2 ti tie Table 6-2 Table 6-2
14. 188 of ,188 188 of 188 A
  • Added parentheses to "continued" in Table 6-2 title Table 6-2 Table 6-2

- --** ~ - -- -- - --

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