ML19308D619

Tech Spec Change Request 16 Re ETS 1.17 & 2.4,providing for Use of Single Term & Definition of Phrases, Detectable Concentrations & Lower Limit of Detection

ML19308D619
Person / Time
Site:	Crystal River
Issue date:	12/14/1977
From:	FLORIDA POWER CORP.
To:
Shared Package
ML19308D617	List: ML19308D616 ML19308D618 ML19308D619
References
TAC-07763, TAC-7763, NUDOCS 8003050817
Download: ML19308D619 (8)

Text

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- V TECHNICAL SPECIFICATION REQUEST N0. 16 (ETS)

Replace pages 1,1-3, 2-17, 2-18 and 2-19 with the attached revised pages i, 1-3, 2-17, 2-18 and 2-19.

Proposed Change 1.

To Section 1.0, add the title "1.17 Lower Limit of Detection" to page i and add the definition "1.17 Lower Limit.... is present" to page 1-3.

e 2.

To Tables 2.4-1 and 2.4-2, change the column heading from " Detectable Concentration" to " Lower Limit of Detection."

3.

To Table 2.4-1, change Note "(3)" to "(2)" and Note "(2)" to "(3)."

4.

To Table 2.4-1, delete "Ba-La-140, I-131" as the second line under column marked " Type of Activity Analysis" and change the first and second lines under th 1,umn marked " Detectable Cogn$ rations" and "10- " to "5 x 10-7pI from present "5 x 10-5.

To the notes to Table 2.4-1 on page 2-18, change Note (2) to "The stated lower...should be reported." and change Note (3) to "The a_ priori; lower...

. emitters in the samples."

Reason for the Procosed Chance:

The phrases " Detectable Concentrations" and " Lower Limit of Detection" are utilized in Sections 2 and 3 of the ETS. The above changes provide for the use of a single term and definition.

The Lower Limit of Detection for Cu-64 by Ge(Li) Spectroscopy is restricted t

by it's photon abundance of 0.005 and half life of 12.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. An LLD of 5 x 10-7 uCi/ml cannot be achieved with this system. Secondly, as sample activity increases, the currently specified limits may be exceeded for other nuclides such as Cr-51 due to the increased background counts in the spectral region of interest, 8003 050 fj')

A ENVIRONMENTAL IMPACT OF THE PROPOSED CHANGE The effect of ummeasured effluent activity upon the environnent is not changed. As an example, the prc00 sed a. priori LLD for Cr-51 is 5 x 10-7/ 0.099 and thus 5 x 10-6 uCi/ml.

Secondly, a study has been conducted to verify that a posteriori LLDs do increase as sample activity increases. The Crystal River liquid waste data base contains all measured activity and LLD values for each batch release. This data includes LLD values that exceed 5 x 10-7 uCi/ml (Cu-64 and occasionally Cr-51 and others).

The volume,of waste released during the first'three quarters of 1977 was 1.1 x 100, 1.3 x 100 and 9.7 x 100 liters respectively. No significant changes were made to the analytical system during this period.

Jigure 1 provides a comparison of the projected individual dose rates (LLD and measured gamma emitters) as calculated with the LADTAP. Code. These dose rates are presented as a function of the annual rate of release of gamma emitting radionuclides as measured prior to discharge. The significance of the LLD dose rate is shown to decrease as measured effluent activity and it's dose commitment increase. The degradation of LLD values with increased sample activity is also confirmed. Since this dose projection from unmeasured activity is not altered by the proposed changes and since the LLD dose contribution represents a small fraction of the 10CFR-50 Appendix I limits, there is no environmental impact from the proposed change.

BENEFIT - COST ANALYSES OF THE PROPOSED CHANGE As stated above, there will be no environmental cost as a result of the proposed change. The benefits are that an improved means for specifying the measurement capability of analytical systems is provided and a means of demonstrating the significance of unmeasured activity is suggested by_ Figure 1.

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7 ACTIVITY Ci/Y FIGL3E I Comparisen of the calculated individual dose rates resulting from LLD and =easured activities of ga=ma emitters as a function of the release rates of measured ga=ma emitters at Crystal River Unit 3.

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TABLE OF CONTENTS Page No.

1.0 DEFINITIONS e

1-1 1.1 Frequency 1-1 1.2 Gross (8,y) Analysis 1.3 Point of Discharge (POD) 1-1 1.4 AT Across the Condenser 1-1 1-1 1.5 Unit 3 Mixing Zone 1-1 1.6 Emergency Need for Power 1-1 1.7 Abnormal Power Operation 1.8 Known Radioactive Source 1-3 1-3 1.9 Intake Area 1-3 1.10 Discharge Area 1-3 1.11 Inner Bay 1-3 1.12 Outer Bay 1-3 1.13 Channel Calibration l.14 Channel Check 1-3

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1.15 Channel Functional Test 1 1.16 Dose Equivalent I-131 1-3 1.17 Lower Limit of Detection 1-3 2.0. LIMITING CONDITIONS FOR OPERATION 2.1 Thermal 2-1 2.1.1 Maximum 4T Across Condenser 2-1 2.1.2 Maximum Discharge Temperature 2-2 2-3 2.2 Hydraulic 2.3 Chemical 2-3 2.3.1 Biocides 2-3 2.3.2 Corrosion Inhibitors 2-4 2.4' Radioactive Effluents 2-4 2.4.1 Liquid Waste Effluents 2-5 2.4.2 Caseous Waste Effluents 2-9 2.4.3 Solid Waste Handling and Disposal 2-16 3.0 ENVIR0hMENTAL SURVEIIIANCE 3.1 Nonradiological Surveillance 3-1

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1.8 Known Radioactive Source - A calibration source which is traccable

,l to the National Bureau of Standards radiation measurement system and is capable of reproducible geometry.

1.9 Intake Area - The intake canal and all of the water area south of the north intake dike and within two miles of the west tip of the south intake, dike.

1.10 Discharge Area - The discharge canal and all of the water area north of the south discharge dike and within two miles of the north dis-charge dike.

1.11 Inner Bay - An area as shown in Figure 1.1-2 which is five feet or less in depth composed of a mixture of grassy bottems, oyster associa-tions, algal bottoms and areas of sand and mud.

1.12 Outer Bav - The outer basin as shown in Figure 1.1-2 in which the planktonic ecosystem becomes as important as the bottom ecosystems.

1.13 Channel Calibration - The adjustment, as necessary, of the channel output such that it responds with necessary range and accuracy to known values of the parameter which the channel monitors.

The channel calibration shall enec= pass the entire channel including the sensor and alarm and/or trip functions, and shall include the channel func-tional test.

Channel calibration =ay be perfor=ed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.

1.14 Channel Check - The qualitative assessment of channel behavior during operation by observation.

This determination shall include, where possible, ec=parison of the channel indication and/or status with other indications and/or status derived frem independent instrument channels measuring the same parameter.

1.15 Channel Functional Test - The injection of a simulated signal into the channel as close to the primary sensor as practicable to verify operability including alarm and/or trip functions.

1.16 Dese Equivalent I-131 - That concentration of I-131 (uci/ gram) which alone would produce the same thyroid dose as the quantity and iso-topic mixture of I-131, I-132, I-133, I-134 and I-135 actually present.

The thyroid dose conversion factors used for this calculation shall

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be those listed in TID-14844.

1.17 Lower Limit of Detection (LLD) - The smallest quantity of radioactive material for which there is confidence at the 0.95 level that activity I

is present.

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.m Table 2.4-1 RADIOACTIVE LIQUID SAMPLING AND ANALYSIS Lower Limit f Detection Liquid Sampling Type of Source Frequency & Analysis Activity Analysis (pC1/ml) (2)

A.

Batch Releases to (3)

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the Environment Each Batch (Grab Sample)

Principal Carama Emitters S x 10~ 7/ 1 One Batch / Month (Crab Sample)

Dissolved Cases (5) 10~

Monthly Cornposite(

11 - 3 10~

(From Grab Samples)

Cross a 10

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-8 Sr-90, Sr-89 10 x 10 y

C Biweekly (4}

I-131, 1-133 10 B.

Priinary Coolant At least

-6 C.

Low Power Cencrator Commencement of Bleeds Bleed (Crab Sample)

Cross 8 5 x 10-

-7 Every 4 hrs during Bleed Gross 6 5 x 10 1

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s 2-18 Table 2.4-1 (Continued)

NOTES:

(1) A Composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged.

(2) The stated lower limits of detection, determined on a sample blank, are based on technical feasibility and on the potential significance in the environment of the undetected quantities released.

Lower detection limits may be readily achievable and when nuclides are measured below the stated limits, they should be reported.

(3)

The a, priori lower limit of detection for an individual gamma e=itter is stated as a function of the photon abundance I (expressed as a decimal fraction).

The a, posteriori LLD for a particular measurement may be adversely affected by the presence of other ga=ma emitters in the sample.

(4)

The power level and cleanup or purification flow rate at the sample time shall also be reported.

-5 (5)

For dissolved noble gases in water, assume an MPC of 4 x 10 CW1 of water.

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j RADIOACTIVE GASEOUS WASTE SAMPLING AND

. LYSIS FREQUENCY Lower Limit Gaseous Samp!ing and Analysis Type of of Detection Source Frequency Activity Analysis (pCi/ml) (I)

A.

' Waste Gas Decay Each Tank (Grab Sample)

Principal Camma Emitters 10~

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Tank Releases Release 11 - 3 10

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r Each Purge Principal Gamma Emitters 10 T.

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Condenser Air Ejector Weekly'(Grab Sample)

Principal Gamma Emitters 10

-6 Monthly (Grab Sample) 11 - 3 10 i

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Environmental Release Weekly (Gas Grab Sample)

Prinicpal Gamma Emitters 10~

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~0 Points Monthly (Gas Grab Sample) 11 - 3 10 (On Line 141S)

Weekly (Charcoal Filter)

I-131 10~

(On Line 141S)

-10 Weekly (Charcoal Filter)

I-133, I-135 10 (On Line RMS) 7 Weekly (Particulate Filter)

Principal Camma Emitters (Ba-La-140, I-131 and others) 10~

Honthly Coirposite

-11 (Particulate Filters)

Gross a 10 Monthly Composite Sr 89,

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