ML20033D973
| ML20033D973 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/09/1988 |
| From: | Liza Cunningham Office of Nuclear Reactor Regulation |
| To: | Samworth B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20033D974 | List: |
| References | |
| FOIA-92-581 TAC-69278, NUDOCS 8811150151 | |
| Download: ML20033D973 (7) | |
Text
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UNITED sT ATEs NUCLEAR REGULATORY COMMISSION-
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hW 09198E Docket No. 50-397 MEMORANDUM FOR: Robert B. Sarworth, Project Manager Project Directorate V Division of Reactor Projects III/IV/V and Special Projects Office of Nuclear Reactor Regulation FROM:
LeMoire J. Cunningham, Chief Radiation Protection Branch Divisict of Radiation Protection and Emergency Preparedness.
Office of Nuclear Reactor Regulation
SUBJECT:
TIA 88-19 REQUEST FOR ASSISTANCE FROP REGION V CONTAINED IN AUGUST 20, 1988 MEMORANDUM FROM P. A. SCARANG RELATIVE TO SAMFLING OF THE DRYWELL ATk0 SPHERE AT WNP-2 PRIOR TO RELEASE The subject mecorandur with attached NRC Inspection Report of WNP-2 dated August 19, 1986 requested assistance in interpretation of two current WNP-2 Technical Specifications (TS): TS 3/4.11.2.1 (Enclosure 1) and TS 3/4.11.2.0 1
(Enc 1csure 2). Specifically, the memorandum asks: "In view of the licensee's interpretation as found and described in the enclosed report, does Technical l'
Specification 4.11.2.1 and Table 4.11-2 require a sample of drywell atmesphere be taken and analyzed prior to each vent and/or purge operation threugh the i
Stardby Gas Treatment (SGT) system?" It also asks: "If prior-to-r'elease samples are required, should this be reflected in the ODCM, along with appro-i priate decontamination factor to account for SGT cleanup?"
We have reviewed the detailed information in the inspection report documenting
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the positions of the inspector and the licer.see in regard to the subject questien. We agree with the position expressed by the licensee's Corporate Nuclear Safety Review Boaro (CNSRB) merber at the November 27, 1985 meeting of their Plant Operations Committee (POC) recorded on pages 10 and 11 of the Inspection Report. WNP-2 TS 4.11.2.1.2 with its Table 4.11-2 requires that c grab sample be taken prior to each PURGE and VENT from Primary Containment.
TS 4.11.2.8.3 provides additional requirements for the case of PURGING or VENTING through other than the SGTS, but says nothing about when the SGTS is used. The APPLICABILITY of TS 3/4.11.2.1 is "At all times." Therefore the answer to the first question of Region V is "YES".
- x. _. 1 CONTACT:
L Wayne Meinke, NRR 492-3152 g
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k Robert B. Samworth NOV 0 9199g In regard to the second question, TS 4.11.2.1.2 ties the sampling and analysis program of Table 4.11-2 to dose rate detenninations "in accordance with the methodology and parameters in the ODCM." Thus statements regarding these deteruinations should be incorporated in the ODCM.
Ori iral si ncHy LCitt i D :s' E
i LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Reculation
Enclosures:
1.
TS 3/4.11.2.1 2.
TS 3/4.11.2.8 i
r Distribution:
FJCongel, NRR LJCunningham, NRR THEssig, NRR JEWigginton, NRR WKeinte, NRR WDTravers, NRR RJEarrett, NFR RLAnderson, TTC Central Files RPB R/F
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. ENCLOSURE I i
t RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS i
DOSE RATE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the following:
a.
For noble gases:
Less than or equal to 500 mrems/yr to the total
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body and less than or equal to 3000 mrems/yr to the skin,.and j
b.
For iodine-131, for iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days:
Less than or equal to 1500 mrems/yr to any organ.
APPLICABILITY:
At all times.
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ACTION:
t With the dose rate (s) exceeding the above limits, immediat'ely restore a.
the release rate to within the above limit (s).
b.
The provisions of Specification 6.9.1.9.b are not applicable.
SURVEILLANCE REQUIREMENTS ThedoserateduetonoblegasesingaNouseffluentsshallbe 4.11.2.1.1 determined to be within the above limits in accordance with the methodology
.l and parameters in the ODCM.
I The dose rate due to iodine-131, iodine-133, tritium, and all 4.11.2.1.2 i
radionuclides in particulate form with half-lives greater than 8 days in
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gaseous effluents shall be determined to be within the above limits in_accordance tsith the methodology and parameters in the ODCM by obtaining representative
. samples and performing analyses in accordance with the sampling and analysis j
program specified in Table 4.11-2.
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I WASHINGTON NUCLEAR - UNIT 2 3/4 11-8
TABLE 4.11-2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM fi5 5
LOWER LIMIT OF a
MINIMUM DETECTION (LLD)a SAMPLING ANALYSIS TYPE OF R
GASEOUS RELEASE TYPE FREQUENCY FREQUENCY ACTIVITY ANALYSIS (pCi/mL) z R
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-4 D
D A.
Primary Containment Each PURGE Each PURGE Principal Gamma Emitters 1x10 PURGE and VENT and VENT and VENT
-6 c-1x10 Grab Sample M
-4 M 'd l
Principal Gamma Emitters #
D 1x1r B.
Main Plant Vent b
-6 H-3 1x10 I
-4 C.
Turbine Building M
M Principal Gamma Emitters 1x10 Vents and Radwaste Grab Sample
-6 H-3 1x10 y
Building Vents
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D.
All Release Types Continuous
- W I-131 1x10_
c as listed in A, Charcoal Sample I-133 1x10 8, and C above Principal Gamma Emitters #
1x10"Il C
Continuous' W
Particulate Sample
~11 Continuous
- M Gross Alpha 1x10 Composite Par ticulate Sample 1x10"Il Continuous' Q
Sr-89, Sr-90 Composite Par-ticulate Sample
-6 Continuous' Noble Gas Noble Gases 1x10 Monitor Gross Beta or Gamma (Xe-133 equivalent)
TABLE 4.11-2 (Continued)
TABLE NOTATIONS lhe LLD is defined, for purposes of these specifications, as the smallest a
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:
D LLD =
E V
2.22 x 108 Y
exp (-AAI) s Where:
LLO is the "a priori" lower limit of detection as defined above, as microcuries per unit mass or volume, is the standard deviation of the background counting rate or of sthe counting rate of a blank sample as appropriate, as counts per h
- minute, E is the counting efficiency, as counts per disintegration, i
V is the sample size in units of mass or volume, 2.22 x 106 is the number of disintegrations per minute per microcurie, Y is th'e fractional radiochemical yield, when applicable,
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A is the radioactive decay constant for the particular radionuclide, P
and for plant effluents is the elapsed time between the midpoint of At sample collection and time of counting.
Typical values of E, V, Y, and at should be used in the calculation.
It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
WASHINGTON NUCLEAR - UNIT 2 3/4 11-10
TABLE 4.11-2 (Continued)
TABLE NOTATIONS I
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bSampling and analysis shall also be performed following shutdown, startup, or a THERHAL POWER change exceeding 15% of RATED THERKAL POWER within a j
1-hour period.
t Samples shall be changed at least once per 7 days and analyses shall be c
l completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing, or after removal from sampler.
Sampling shall also be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for at least 7 days following each shutdown, startup, or THERMAL POWER change exceeding 15% of RATED THERHAL POWER in I hour and analyses shall be completed within 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> of changing. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are l
analyzed, the corresponding LLDs may be increased by a factor of 10.
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This requirement does not apply if (1) analysis shows that the DOSE EQUlVALENT I-131 concentration in the primary coolant has not increased more than a factor of 3; and (2) the noble gas monitor shows that effluent activity has not increased more than a factor of 3.
dTritium grab samples shall be taken at least once per 7 days from the main plant vent stack to determine tritium releases in the ventilation I
exhaust from the spent fuel pool area whenever spent fuel is in the spent l
fuel pool.
'The ratio of the sample flow rate to the sampled stream flow rate shall j
j be known for the time period covered by each dose or dose rate calcula-i tion made in accordance with Specifications 3.11.2.1, 3.11.2.2, and 3:11.2.3.
i The principal garca emitters for which the LLD specification applies
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include the following radionuclides:
Kr-87, Kr-8S, Xe-133, Xe-133m,
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l Xe-135, and Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, j
Co-60, 2n-65, Ho-99,1-131, Cs-134, Cs-137, Ce-141 and Ce-144 in iodine and particulate releases. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, j
together with those of the above nuclides, shall also be analyzed and reported in the Semiannual Radioactive Ef fluent Release Report pursuant to Specification 6.9.1.11.
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WASHINGTON NUCLEAR - UNIT 2 3/4 11-11
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RADI0 ACTIVE EFFLUENTS VENTING OR PURGING LIMITING CONDITION FOR OPERATION 3.11.2.8 VENTING or PURGING of the Mark 11 containment drywell shall be through the standby gas treatment system or the primary containment vent and The first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any vent or purge operation shall be.
purge system.
through one standby gas treatment system.
APPLICABIllTY: Whenever the drywell is vented or purged.
ACTION:
With the requirements of the above specification not satisfied, a.
suspend all VENTING and PURGING of the drywell.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
b.
SURVEILLANCE REQUIREMENTS The containment drywell shall oe determined to be aligned for VENTING 4.11.2.8.1 or PURGING through the standby gas treatment system or the primary containment vent and purge system within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to start of and at least once per
-l 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during VENTING or PURGING of the drywell.
Prior to use of the purge system through the standby gas treatment 4.11.2.8.2 system assure that:
Both standby gas treatment system trains are OPERABLE whenever the j
a.
purge system is in use, and i
e Whenever the purge system is in use during OPERATIONAL CONDITION 1 b.
or 2 or 3, only one of the standby gas treatment system trains may l
be used.
The containment drywell shall be sampled and analyzed per 4.11.2.8.3 Table 4.11-2 of Specification 3.11.2.1 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the start of l
and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during VENTING and PURGING of the drywell l
through other than the standby gas treatment system.
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b
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WASHINGTON NUCLEAR - UNIT 2 3/4 11-18 l
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