ML18150A091

Proposed Changes to Tech Spec 4.9, Effluent Sampling & Radiation Monitoring Sys, to Correct Error Noted in Insp Rept 84-32 & to Conform to NUREG-0472.Util Safety Evaluation Encl

ML18150A091
Person / Time
Site:	Surry
Issue date:	05/14/1987
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18150A090	List: ML18150A089 ML18150A091
References
RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 8705260084
Download: ML18150A091 (11)

Text

• , e e ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGE SURRY POWER STATION UNITS 1 AND 2

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8705260084 870514 PDR ADOCK 05000280 P PDR..

TABLE 4.9-4 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Water Airborne Particul~te Fish Milk Food Products Analysis (pCi/1) or Gases (pCi/m) (pCi/kg, wet) (pCi/1) (pCi/kg, wet) e H-3 30,000 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 I-131 2* 0.9 3 100 el Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 H

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• Reporting Level for the Ground (drinking) Water Samples required by Table 4.9-3. The Reporting Level for the Surface .-P-(non-drinking) Water Samples required by Table 4.9-3 is 20 pCi/1. \..0 I

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TABLE 4.9-5 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSISa LOWER LIMIT OF DETECTION (LLD)b Water Airborne Partic:llate Fish Milk Food Products Sediment Analysis (pCi/1) or Gas (pCi/m) (pCi/kg, wet) (pCi/1) (pCi/kg, wet) (pCi/kg, dry) gross beta 4 0.01 e

H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 I-131 le 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 t-3 Ct:l La-140 15 15 ~

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w Note: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

TS 4.9-14 TABLE 4.9-5 (Continued)

TABLE NOTATION a

Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

b Table 4.9-5 indicates acceptable detection capabilities for radioactive materials in environmental samples. These detection capabilities are tabulated in terms of the lower limits of detection (LLDs). The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count (above system background) that will be detected with 95%

probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

E

• V

• 2

• 2 2

• Y

• exp ( - A Ll t)

Where:

LLD is the "a priori" lower limit of detection as defined above (as picocuries per unit mass or volume),

sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute),

e e TS 4.9-15 Eis the counting efficiency (as counts per disintegration),

Vis the sample size (in units of mass or volume),

2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield (when applicable),

A is the radioactive decay constant for the particular radionuclide, and

~t for environmental samples is the elapsed time between sample collection (or end of the sample collection period) and time of counting Typical values of E, V, Y, and ~t should be used in the calculation.

It should be recognized that the LLD is defined as an~ priori (before the fact) limit representing the capability of a measurement system and not as~ posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report pursuant to Specification 6.6.b.2.

C LLD for the Ground (drinking) Water Samples. The LLD for the Surface (non-drinking) Water Samples is 10 pCi/1.

e ATTACHMENT 2 SAFETY EVALUATION SURRY POWER STATION UNITS 1 AND 2

SAFETY EVALUATION NRC Inspection Report 84-32 dated December 12, 1984 for Surry Power Station Units 1 and 2 noted an error in Technical Specification 4.9, "Effluent Sampling and Radiation Monitoring System." Specifically, Table 4.9-4, "Reporting Levels for Radioactivity Concentrations in Environmental Samples,"

and Table 4.9-5, "Detection Capabilities for Environmental Sample Analysis" list the reporting level for I-131 in water as 2 pCi/liter while the lower limit of detection level is shown as 10 pCi/liter. Subsequent to the inspection, it was determined from the inspector's discussions with the Office of Nuclear Reactor Regulation (NRR) that 2 pCi/liter was in accordance with official guidance. However, it was recognized and so stated in Inspection Report 84-32 that this could result in reporting levels of little significance. The proposed Technical Specification changes address these points.

Table 4.9-4 has a reporting level of I-131 for water as 2 pCi/liter. The proposed change to Table 4.9-4 has a reporting level of I-131 for ground (drinking) water samples as 2 pCi/liter and a reporting level of I-131 for surface (non-drinking) water samples as 20 pCi/liter. This proposed change is consistent with Inspection Report 84-32 in which the inspector informed the Company that NRR would consider a request to increase the reporting level to 20 pCi/liter consistent with other environmental reporting levels.

Table 4.9-5 has a lower limit of detection of I-131 for water as 10 pCi/liter.

The proposed change to Table 4.9-5 has a lower limit of detection of I-131 for ground (drinking) water samples as 1 pCi/liter and as footnoted on TS 4.9-15, a lower limit of detection of I-131 for surface (non-drinking) water samples as 10 pCi/liter. This change is in accordance with NUREG 0472, Radiological Effluent Technical Specifications for PWRs, Revision 3. This change also inserts symbols that have been inadvertently deleted on TS 4.9-15.

10 CFR 50.59 Safety Review The proposed change will not result in an unreviewed safety question as defined in 10 CFR 50.59. Specifically,

1. the revised specifications will not increase the probability of occurrence of any malfunction or accident addressed in the UFSAR.

This change is being made to conform to NUREG 0472 and other NRC guidance.

2. no new accident types or equipment malfunction scenarios will be introduced as a result of operating in accordance with the revised specifications. The proposed change does not involve or affect plant operation, but is limited only to environmental sample reporting and detection criteria.

3. since the existing safety analyses will remain bounding, there is no reduction in any safety margin.

e 10 CFR 50.92 Significant Hazards Determination Pursuant to 10 CFR 50.92, the proposed change does not involve a significant hazards consideration because operation of Surry Units 1 and 2 would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change only involves reporting and detection levels for environmental sampling of water during routine operation and as such does not involve or affect the probability or consequences of a previously evaluated accident.

2. create the possibility of a new or different kind of accident from any accident previously identified because the proposed change will not modify or alter an existing plant system. As noted above, since the proposed change involves only the reporting and detection levels for environmental sampling of water during routine operation, it does not create the possibility of a new or different kind of accident.

3. involve a significant reduction in a margin of safety. The change is being requested to make Section 4.9 of Surry's Technical Specif-ications consistent with NUREG 0472, Radioactive Effluent Technical Specifications for PWRs, Revision 3 and NRC guidance received through Inspection Report 84-32. This change on+Y affects environ-mental sampling criteria. It does not affect, nor is it related to, plant operational safety.

Therefore, pursuant

• e to 10 CFR 50.92 based on the above consideration, it has been determined that this change does not involve a significant hazards consideration.

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• e Attachment 3 Voucher Check Surry Power Station Units 1 and 2