ML20024G630

Application for Amend to License DPR-22,correcting Discrepancies Found in Change 2

ML20024G630
Person / Time
Site:	Monticello
Issue date:	10/31/1973
From:	Larkin W NORTHERN STATES POWER CO.
To:
Shared Package
ML20024G629	List: ML20024G628 ML20024G630 ML20024G632
References
NUDOCS 9102130515
Download: ML20024G630 (15)

Text

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l'NITED STATES ATR11C DiERGY CGDf1SSION I

NORTHERN STATES POWER CalPANY Monticello Nuclear Generating Plant Docket No. 50-263 REQl'EST POR AUTHORIZATION OP '

A CILANCE IN TECICi1 CAL SPEC 1PICATIONS OF APPENDIX A PROVISIONAL OPERATING LICCISE NO. DPR-22 (Change Request Dated October 31, 1973)

Northern States Power Company, a Minnesota corporation, requests authorization for changes to the Technical Specifications as shown on the attachments labeled Exhibit A and Exhibit B. Exhibit A describes the proposed changes along with reasons for change. Exhibit B is a set of Technical Specification pages incorporating the proposed changes.

This request contains no restricted or other defense infomation.

NORTHERN STATES POWER C@iPANY By

/' i Wade Larkin Group Vice President - Power Supply On this e S day of (f m . I.No ), 1973, before me a notary public in and for said County, personally appeared Wade Larkin, Group Vice President - Power Supply, and being first duly sworn acknowledged that he is authorized to execute this document in behalf of Northern States Power Company, that he knows the contents thereof and that to the best qf his knowledge, infomation and belief, the statements made in it are',tonc and tha.t,it is not interposed for delay.

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John J'Smitih

($UllU }

o Notary Phlic, llennepin County, Minnesota JOHN J. $M:iH No.w pm . he na.n n co uro, y en, i

, cc. .in,.n tap'.. u.nh :.to c 9102130515 731031 PDR ADOCK 05000263 P PDR

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MONTICELIA NUCLEAR GENERATING P1 ANT DOC);ET NO. 50-263 CllANGE REQUEST DATED october 31, 1973 PROPOSED Cl!ANGES TO Tilt TECilNICAL SPECIFICADONS '

APPENDIX A 0F PROVISIONAL OPEPATING LICENSE NO. DPR 2'  ;

i Pursuant to 10CTR50.59, the holders of the above mentioned license hereby pro-pose the following changes to Appendix A, Technical Specifications, to be placed in oficct during and at the conclusion of operational testing of the Modified Off gas System:

1. Technten! Specification Revisions Contained in ChanRe No. 2 to Provisional Operatine License DPR-22 (Attachment A to Ictter from R S Boyd, Asst Director for BWR's, Division vt Reactor Licensing, USAEC, dated January 14, 1972)

PROPOSED CllANGE Delete all of the revisions contained in Change No. 2. s PEASON FOR CRANGE Change No. 2 was intended to be placed into effect following completion of the augmented off-gas system. We believe the revisions contained in Change No. 2 are inadequate for the following reasono:

a. The trip point for the air ejector radiation monitors was inadvertently deleted,

b. No trip point for the stack radiation monitors was given,

c. There is no provision for plant. operation with one air ejector ,

radiation monitor out of service.

d. No provision was made for plant operation in the event that both off-gas recombiner trains or storage compressors are inoperable,

c. No changen to the existing Bases for Specifications 3.2, 4.2, i and 3.8/4.8 were mad by Change No. 2. Without additional revisions these Bases will contain numerous errors. l

f. Definitions of Q1 and QRS were deleted from Specification j 3.6.A. j

g. Specifications citing the deleted annual average release rate were not corrected.

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, EX111 BIT A 3 2 1

i h. No surveillance requirements were specified for calibration 1 and monitoring of the off-gas storage tank radiation monitors.

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1. No maximum gross radioactivity specification was set for the off-gas storage tanks.

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t 2. Specificat ion 3.2.D. Air Ejector of f-Cas System PROPOSED CllAf;CE >

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l Change Specification 3.2.D to read ,

$ D. Air Ejector Off-gas System 3

1. Except as specified in 3.2.D.2 and 3.2.D.3, both steam jet air 3 ejector off-gas radiation monitors shall be operabic during

] reactor power operation. The trip settings for the air ejector  !

1 monitors, except as specified in 3.2.D.4, shall be set to close  ;

j vithin 30 minutes the recombiner train inlet valve (s) at a Icvel not to exceed the equivalent of 270,000 microcuries j per second af ter a decay time of 30 minutes.

2. Trom and af ter the date that one of the two steam jet air

! ejector off-gas radiation monitors is made or found to bc l inoperabic, continued reactor power operation is permiscible provided the inoperable radiation monitor instrument channel

is tripped.

3. L'pon loss of both steam jet air ejector off-gas radiation ,

monitors, an orderly shutdown shall be initiated and the

, reactor shall be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l 4. If operation is necessary with the off-gas lloldup System recombiners j bypassed, the steam jet air ejector radiation monitors

shall be set to close the off-gas isolation valve instead of the recombiner inlet valves with a delay time not to exceed 15 minutes.

REASON FOR CilANGE The steam jet air ejector radiation monitor trip setting is currently based on the 15-minute average release limit of 2.7 Ci/sec. The 15-minute l everage release limit is to be deleted and a new basis for the monitor i trip setting is required. Establishing the trip setting at a value equivalent to the new maximum release rate of 270,000 uCi/sec at the stack will assure off-gas isolation prior to releases in excess of l this limit.

With the recombiners in operation, the holdup time in the off-gas delay pipe is at least two hours. The proposed 30 minute delay in closure of the recombiner inlet valves to permit plant action to reduce effluent levels is therefore conservative. With the Off-ga. L!hp Rystem recombiners by-passed, the holdup time in the off-gas delay pipe is ar least 30 minutes.

! The proposed 15 minute delay in closure of the off-gae isolation valve to permit plant action to reduce effluent leoels is therefore conservative.

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j 3. Specification 1.,2.T.2. Reactor Building Ventilation plenum Radiatien Monitors l PROP 0c,ED CHAN';E M

j Change Spec.ficction 3.2.E.2 to read:  !

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2. The radiation monitors shall be set to trip as follows:

$ (a) Ventilation plenum 3: 3mR/hr 4

(b) Refuelfug floor h 100mR/hr l

} REASON t'OR CRANCE The new maximum release limit for the Reactor Building Vent is 21,000

) uC1/sec of gross radioactivity. A trip setting of 3mR/hr has been es- t j tablished by AEC Staff calculations as being equivalent to thde release >

{ limit.

4 Tatte 4.2.1 l PROPOSED CHANGE l

j Change the Of f Cas Idolution portion of the table to read as follows:

Instrument Channel Test (3) Calibration (3) Sensor Check (3)

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off Cns isolation Radiation bbnitors Notes (1.5) Note 6 Once/ shift

{ (Air Ejectort.)

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REA90N FOR CHANCE j This change will clarify the method of calibration to be used on the steam jet air ejector radiation monitors. Note 6 requires a calibration cach quarter using the built-in current source and a calibration each 4 refueline outace using a known radioactive source.

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5. 3.2 Bases PROPOSED CHANGE 1

Chance the second paragraph on page 68 to read:

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iwo air ejector of f-gas monitors are provided and when their trip point is reached, cause an isolation of the air ejector i

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EX)llBIT A 4-t off-gas line. Isolation is initiated when both instruments reach their high trip point or one has an upscale trip and the other a downscale trip or two dovnscale. There is a 30-minute delay before recombiner train inlet valve closure  ;

when the recombiners are in use and s 15-minute delay '

before of f-gas isolation valve closure when the recombiners are bypassed in which the reactor operator may take corrective action, both instruments are reautred for trip. The trip settings of the instruments are set so that the maximum stack release rate limit allowed by Specification 3 6.A.1 is not ex-ceeded. . i Change the fourth sentence in the third paragraph on page 68 to read:

Trip settings of 3 mR/hr for the tenitors in the ventilation duct are based upon initiating normal ventilation isolation and Standby Gas Treatment System operation so as not to exceed the maximum release rate limit allowed by Specification 3.8.A.1 for the reactor building vent of 21,000 mierecuries per second of gross redioactivity.

REASON FOR CHANGE The proposed change corrects the Bases to reflect the installation of the Dif-gas lloldtp System and the reduced Reactor Building Ventilation plenum Radiation Monitor trip setting.

6. Specification 3.8.A. Airborne Effluents PROPOSED CilANEE Change Specification 3.S.A to read:

A. Airborne Effluents A set of equations are given to express the airborne effluent limits. The symbols stand for the following:

Q1 = release rate from off-gas stack QRS = release rate from reactor building vent

1. The maximum release rates of Eross radioactivity co=puted on a 15-minute average basis shall not exceed a rate Q. in curies /sec:

01 + QRS h1 0.27 0.021

2. The release rates of gross radioactivity shall not exceed 16 percent of the limit in Specification 3.6.A.1 averaged over any calendar quarter.

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3. The maximum release rate of radioiodine.

131 (1-131) shall not exceed a rate Q in ,

j microcuries/ sect 1 4

l @ + QRJ 6 1 f

{ 25 1.2 l 1

{ 4. The release rate of 1-131 shall not exceed t 4 percent of the limit in Specification l 3.8.A.3 averaged over any calender quarter.

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{ 5. The maximum release rates of radioactive l particulates with half-lives greater than 8 i days shall not exceed a rate Q, in micro-j curies / sect k 01 + ORS i J: 1 l 9.5X101 r2Ca 1.1X16$ RFCa where MPCa is the composite maximum per-missible concentration in air in p01/al l determined usinc Appendix B, 7tble II,  ;

4 Galumn 1 and liates of 10 CFR 20.

l 6. The release rates of radioactive particulates  :

with half-lives greater than 8 days shall not i exceed E perccnt of the limit in Specification i 3.8.A.5 averaged over any calendar quarter.

I 1 7. If the maximum release rate limits of Specifications

! 3.5.A.1, 3.8.A.3, or 3.8.A.5 are not met following a

routine surveillance check, an orderly situtiown shall be

initiated and the reactor shall be in the cold shutdown

. conditior within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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8. If the limits of Fpecifications 3.8. A.2, 3.8. A.4

! or 3.8.A.6 are exceeded, appropriate corrective

action such as an orderly reduction of power l shall be initiated to bring the releases within

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9. If the release rates exceeds four percent of i the limits in Specification 3.8.A.1 averaged

, over any calendar quarter or two percent of the limits in Specifications 3.8.A.3 or 3.8.A.5 averaged over any calendar quarter, the following i

actions shall be taken:

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EXil1 BIT A

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a. Investigate to identify the causes for such release rates, i i t

{ b. Define and initiate a program to reduce such release rates to the design levels.

a c. Provide a report describing t.hese actions  !

j within 30 days as an unusual event (See j Specification 6.7.B.2),

i l' 10. At least one of the two stack monitors, including the charcoal cartridge and particulate filter, shall be operable

' at all times that the stack is releasing effluents to the environs.

! 11. If both stack monitors are made or found inoperable, the

reactor shall be placed in the hot standby condition within '

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.  ;

! 12. Except as specified in 3.8.A.13, the off-gas stack and reactor building vent monitors shall have automatic isolation j setpoints consistent with Specification 3.8.A.1 and alarm j

A retpoints consistent with Specification 3 8.A.2

13. If operation is necessary with the Off-Cas lloldup System recombiners bypassed, the off-gas stack monitors shall serve only an alarm function.

REASON FOR CilANGE i

specifications 3.8.A.1 through 3.8.A.9 are required to bring the Monticello gaseous release limits into agreement with current AEC "ac lov ac practicLtle"

guidelines, i

! Specifications 3.8.A.10 through 3.8.A.13 establish limiting conditions l for operation for the off-gar stack radiation monitors and specify l alarm end trip setpoints for the gaseous effluent monitoring systens.

7. cpceifiention 4.8 A. Airborne Ef fluents i'

PROPOSED CilANCE

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Change Epccifications 4.8.A to read:

i A. Airborne Effluents

1. Station reccrds of gross stock release rate of gaseous activity shall be maintained on an hourly basis to assure that the specified rates are not being exceeded, and to yield i information concerning general integrity of the fuel cladding. Records of isotopic analysis l

i shall be maintained. The off-gas stack and reactor l

building vent tunitoring system shall be func-l tionally tested monthly and calibrated quarterly with an appropriate standard radiation source.

Each monitor, as described. shall have h sensor ,

check at lesst daily.

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2. An air ejector off-goc cample isotopic analysis for at lenet six ficcion product gases; Xe 138, Xe-135, Xe -133, Kr-88, Kr-85m. Kr-87 shall be made at Icast wechly and following each refueling or other occurrence which could alter significantly the mixture of radionuclides.

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"" 3. Gaseous release of tritium shall be calculated on a quarterly basis from the tritium con-centration of the condensate. Vaporous tritieu shall be calculated from a representative smnple.

The sum of these two values shall be rcported 9 as the total tritium release.

4. Station records of release of radioiodines and particulates with half-lives greater than 8 i days shall be maintained on the basis of all stack and vent cartridges counted. The charcoal cartridges shall be counted weekly when the measured release rate of radioiodine-131 activity is less than the rate of Specification 3.8. A.4; otherwise the cartridges shall be counted daily.

The particulate filters shall be counted weekly when the measured release rate of particulate radioactivity with half-lives greater than 8 days is less than the rate of Specificatio.n 3.8.A.6; othereise the activity shall be counted daily. Ibathly the principal particulate rL=a rndionuclider thn11 be determined.

j REASON TOR CHANGE I

The revisions to Specification 4.8. A are required to accompany the changet in Specification 3.8. A which incorporate "as low ac prneticable" guidelines. The changes in sampling frequencies and methods of anclysis reflect current AEC guidance in these areas.

8. Specifications 3.8 L and 4.8.E. Augmented Off-Ras System PROPOSED CHANGE Delete Specification 3.8.E and the first and third paragraphs of 4.8.E.

Renumber Specification 4.8.E as 4.8.T cnd change the Specification title to "Lnviromental Ibnitoring Program". Add new Epecifications 3.6.E cnd L.O.L nt follows:

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, EKilIBIT A 1

3.8.E. Augmented Off-Gas System

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1. 11 the hydrogen concentration in the off-j gas downstream of the recombiners reaches f i four percent, the recon,biner off-gas flow shall be j stopped cutomatically oy closing the valves t

! upstream of the recombiners.

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2. Except as specified in Specification 3.8.E.3 l

, below, at least one hydrogen monitor upstream j -

and one hydrogen monitor downstream of each

, operating recombiner shall be operable during i power operation.

j 3. If the above specified upstream hydrogen monitors ,

j are not operable, continued operation of a re-3 combiner is permissible if the Hydrogen Inventory i Processor is set to provide a constant signal representative of the worst case hydrogen con-

! centration. If the above specified downstream j hydrogen monitors are not operable, an orderly i reactor shutdown shall be initiated to transfer the off-gan System to the recombiner bypass l mode.

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4 The maximum gross radioactivity contained in l one gas decay tank after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> holdup that can be discharged directly to the environs shall j be less thcn 22,000 curies of Xe-133 dose eq-i uivalent. If these conditions cannot be met, the stored radioactive gas shall be recycled j within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to other gas tanks until the condition is met, j

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4.8.E Augumented Off-Cas System 1 1. The hydrogen tonitors shall be functionally j tested monthly and calibrated quarterly with an appropriate gas mixture source. Each monitor l shall have a sensor check at 1 cast daily. ,

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EXil1 BIT A 9

2. Tank radiation monitors shall be calibrated quarterly by correlation with tank sample analyses. Monitor readings shall be recorded every eight hours to de-termine that the limit of Specification 3.8.E.4 is not exceeded.

3. If a tank radiation monitor is inoperable, a sample from the gas decay tank shall be taken, analyzed, and recorded every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If no additions to a tank have occurred since the last sample, the tank need not be sampled until the next addition.

REASON TOR CRM GE The proposed trip point of the hydrogen monitors is four percent hydrogen by volume. This is the lower limit of flamability of hydrogen and vill protect components of the off-gas system from possibic explosion damage.

, In the event that the required upstream monitors are not availabic, the

] llydrogen Inventory processor is set to the worse case hydrogen concentration 1 in the influent stream and will limit off gas flow accordingly. If the l required downstream monitors are not available, operation of the recombiners is not pemitted.

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! Calculations by the Comission staff have determined that limiting the

! contents of a singic gas decay tank which could be released to the

environs to 22,000 Ci of Xe-133 dose equivalent would limit the whole l body dose to less than 20 mh at the plcnt boundary in the event of j accidental tank discharga.

1 The minimum holdup time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is controlled by electrical interlocks in the decay tank selection logic. The 12-hour decay will guarantee at I 1 cast a 907. reduction in tank activity prior to release.

I Off-gas flow rates during plant startup will .torma11y exceed the capacity of the holdup system compressore. During these periods the off-gas is generally of low activity and can be exhausted directly through the off-gas stack.

) Specifications 4.8.E.1 through 4.8.E.3 establish minimum calibration and J monitoring requirements for the Off-gas Holdup System hydrogen monitors and storage tank radiation monitors.

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9. 3.8/4.8.A bases l PROPOSED CHA' CE Dr.lete the fourth paragraph on parc 177.

Change the second and third paragraphs to read as follows

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In order to limit gross radioactivity releases in gaseous effluents to as low as practicable, quarterly average release rates have been established which would require investigative actions at 4 perecnt of the maximum release rate and restricted operation action at 16 percent of the maximum release rate. These release rates are sig-nificantly below 10 CTR 20 limits and are factors of 2 and 8, respectively, above the design objectives.

.N thyreta dore : nl u d n t br.r have Lee c, m' 9 by t he AEC r t e.

T: method it tared en n 2% mhem dore to n chi 2d thnt d ra:.P. the

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• ; 2 r; >. cc: t o.i nl y em.u. tc +.hc .,; rm :..a the critical sector (northwest sector at 1.5 miles). The maximum annual dif fusion parameter (X/Q) f rom the licensee's meteorological data for the stack release is 1.7 X 10'8 sec/n 3. Based on these calculations, a continuous release rate of I-131 in the amount of 25 pCi/sec from the off-gas stack would not result in offsite annual thyroid doses in excess of the limits specified in 10 CTR 20 of 1500 mnea.

Delete the first two paragraphs of 3.8/4.8.A Bases on page 178 and insert the following paragraphs on pager 178, 179, and new pare 179A:

1he AEC staff performed an analysir similar to that used to determine the - aximum relecsc rate for I-131 for radioactive particulates.

A resaction f actor of 700 on the HPCa to allow for possible ecological chalk-ffectssimilartothoseassociatedwithradioiodingwasuged.

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The ar *ual averare dif fusion parameter value of 1.5 X 10~ sec/m was used as detennined for the most critical sector for an elevated release at 600 m in the SSE sector. Based on these calculations, a continous release rate of radioactive particulates with half-lives greater than 8 days in the amount of 9.5 X109 MPca p01/see from the off-gas stack would not result in of fsite manual organ doses in excess of tho limits specified in 10 Crr. 20. The resultant orenn doses are not additive to those caused by the radioiodine or gross rcdioactivity releases.

Th e staff performed similar analysis for the reactor building vent release as for the off-gas stack releases except the releases were considered to be at or near ground level. The maximum annual average diffusion parameter (X/Q) from the licensee's meteorological data for the ground level release as used for radioactive particulates is 1.3x10-5 3cc/n3 The annual average dif fusion parametcr at the nearest existing milk cow as used for the radioiodine is 3.5x10-7 sec/m3.

. EXilZBIT A I

Based on these calculations, a continuous ground Icvel release rate of 1-131 in the amount of 1.2 uCi/sec would not result in off site annual thyroid doses in excess of the limits specified in 10 CFR 20 of 1500 mRen. A continuous ground level release rate of radioactive particulates with half lives greater than 8 days in the amount of 1.1 X 108 FTCn Ci/sec would rot result in of fsite annual organ doses in excess of the limits accified in '

10 CFR 20.

In order to 1.ait radioiodine releases in gaseous releases to as low as practicable, quarterly average release rates have been established which would require investigative actions at 2 percent of the maximum release rate and restricted operation action at 4 percent of the maximum release rate. These release rates are significantly below 10 CFR 20 limits and are factors of 2 and 4 respectively, above the design objectivcs as defined in Regulatory Guide 1.42.

In order to limit radioactive particulate releases in gaseous effluents to as low as practicable, quarterly average release rates have been established which would require investigative actions at 2 percent of the maximum release rate and restricted operation action at 8 percent of .he maximum release rate. These release rates are significantly below 10 CFR 20 limits and are factors of 2 cnd 8, respectively, above the design objectives.

Measurements of the gross radioactivity from the off-gas stack must be continuously monitored for possibic changes in the release rates from the augmented off-gas system. Additicnal measurements are made continuously at the steam jet air ejector to evaluate the core condition and the quantity of radioactivity being added to the augmented of f-gas sys tem. The measurenents obtained by sampling and isotopic analysis define the releases to the environs. Quarterly analysis for tritium is adequate to define such releases to the environs.

Isotopic analysis vill be performed on samples taken from the steam jet air ejector. These saepics will be used in an isotopic analysis for Xe-138, Xe-135, Xe-133, Kr-88, Kr-87, and Kr-85m, which is calculated to be approximatley 90 percent of the noble gas emission.

The remaining noble gases will be calculated from empirical ratios with the measured gases. Such calculations will be made for the various gases down to a release rate of 100 uCi/sec. Argon 41 vill not be measured routinely since it cannot be measured in the presence of the other noble gases.

The measurements and methods used for releases from the reactor b iluing vant are similar to those described for released from the off-gas stack. It may be necessary to use off-gas stack data to evaluate the predicted low 1cvels of release from the reactor building vent. Batch releases may be made during drywell purging or other special con-ditions when continuous monitoring is not availabic. For such conditions, sampling and analysis are required before releases are made and meteorological conditions may be used, if practical, to reduce possible environmental impact for such releases. If the samples indicate high concentrations of either radioiodines and/or radioactive particalates, the releases shall be filtered by the Standby Cas Treatment Systen.

EKilIBIT A Concentrations of gross radioactivity in the reactor building vent are expected to be below the minimum detectable 1cvels with the existing analytical equipment. Therefore, isotopic analyses of sampics from the vent will not normally be performed.

Measurement of the gross radioactivity from the duct to the vent is based upon an equivalent dos. setc for the release rate in curies per second, i.e., analysis of a typical vent gas release resulted in a gamma dose rate of 3 mr/hr being equivalent to 21,000 microcuries/second release rate. Since an isotopic analysis cannot be made routinely of the vent effluent, the assumption is made that the isotopic composition in the vent will bc the same as determined in the off-gas stack.

The release of radioiodine from the reactor is monitored by the use of charcoal cartridges which integrate the releases over the sampling period of one to seven days. Frequency of removal is dependent upon the release level measured on the previously removed charcoal cart-ridge. The relationship between coolant activity levels for radio-iodine and effluent releases during possible iodine spiking conditions has not been determined. Measurements required for such possibic operating conditions that may result in iodine spiking should provide necessary effluent data to the operator to evaluate plant conditions during such periods, The analysis performed for I-133 and I-135 in-dicates the contribution of these radioiodines to the possible in-halation doses.

The release of radioactive particulates with half lives greater than 8 days from the off-gas stack is monitored by the use of particulate filters which integrate the releases over the smnpling period of one to seven days. All other aspects of particulate release measurements are similar to those discussed for radioiodine release measurements except for the relationship of iodine spiking to reactor operating conditions.

REASON TOR CHANCE The proposed change corrects the Lases to reflect the adoption of the "ar 1cw t.c practicable" limitc.

10. 3.8/4.8.E Bases. Augmented Off-gas Svstem PROPOSED CHANGE lbvc Bases 3.8/4.S.8 through 3.S/4.8.D to new pages 179A and 179E.

Renumber Bases 3.8/4.8,E as '3.6/4.8.F and chance the heading to read "Ir.vironmental ibnitoring Program". AddnewBases36/h.8Eonnewpage 17 C cr f:llowr:

E. Augmented Off-gas System The hydrogen monitors ate used to detect possibic hydrogen buildups which could result in a possible hydrogen explosion.

Isolation of the off-gas flow would prevent the hydrogen explosion and possible damage to the augmented off-gas system.

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. EXH1317 A I

i Experience has shown that a daily check with monthly testing and quarter 1*, calibration assures troper operation of the hydrogen monitors and quarterly calibration cssures proper opera' tion of the radiation monitors.

The maximum gross radioactivity in one gas decay tank has been limited on the basis that accidental relence of its content s to the environs by operator error af ter 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> decay should not result in exceedinc the dose equivrtlent to the maximum quarterly relente rate specified in Specification 3.8.A.2. Staff analysis of an elevated release under accident neteoralecy for a minimam release period of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> indicated a release of 22,000 curies of Xe-133 or the dose equivalent would result in a whole body dose of 20 mrem at the nearest site boundary.

The frequency for monitoring or sampling has been established so

that if the maximum amount of gross radioactivity is exceeded, action can be taken to reduce the radioactivity to a level below

! the specified limit.

J PEASON TOP CRANGE i

i The proposed change corrects the Baser to reflect the installation of the off-gas holdup system.

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EXilILIT B f I

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, Exhibit B, attached, consiste of newly prepared paper of the Appendix I A Technical Specifications as listed below which incorporate the l proposed changes:

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