ML20049K059
| ML20049K059 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/01/1982 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20049K043 | List: |
| References | |
| NUDOCS 8203290358 | |
| Download: ML20049K059 (34) | |
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_, , , , M SICHATTD CRIGIHAL 3 CtrLifted By 4k ~ (7 . - . Southern California Edison Company 2-~ S AN ONOFRE NUCLE AR GENER A TING S T A TION P .O. B O X 825 S AN CLEMENTE. C ALIFORNI A 92672 H. B. R A Y TELE'"0NE
. ' vion.A~aa'" February 1, 1982 ' " " " ' " "
- U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Attention: Mr. Frank Wenslawski
Dear Sir:
Subject:
Information Committed to be Provided Region V as a Result of January 29, 1982 Exit Interview by Messrs. Wenslawski and Cillis During the subject Exit Interview concerning the Region's preoperational inspection of the Health Physics inspection modules for San Onofre Unit 2 fuel loading, we enumerated ten specific items of information which would be provided the Region for review. In addition, we committed to provide the Region with a copy of the Technical Specifications related to process and effluent monitors, as marked up at the January 28, 1982 meeting with representatives of the Office of Nuclear Reactor Regulation. Enclosure (1) to this letter identifies the status of each of the ten specific items enumerated at the January 29, 1982 Exit Interview. That status reflects the fact that four of the ten
, items are provided as Enclosures (2), (3), (6) and (7) to this letter; another item is partially provided by Enclosures (4) and (5) to this letter; and all remaining items will be provided by February 5, 1982. Information provided as enclosures to this letter includes all items identified by Messrs. Wenslawski and' Cillis as necessary to permit favorable input (in the areas of their inspection) by the Region to the Office of Nuclear Reactor Regulation regarding our preparedness for fuel loading at' Unit 2, with the exception of item 8. (training), which will be p.rp.vided by February 4, 1982. t--
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t Regulatory Commission February 1, 1982 With respect to the forwarding of a copy of the marked-up Technical Specifications related to process and offluent monitors, that will be received by you under separate cover on February 2, 1982. If you have any questions concerning the information forwarded by this letter, or require additional information, please let me know. Hf>% 7 l1% ~q L
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Enclosure (1) INFORMATION COMMITTED TO BE PROVIDED i REGION V AS A RESULT OF JANUARY 29, 1982 EXIT INTERVIEW BY MESSRS. WENSLAWSKI AND CILLIS ITEM STATUS
- 1. Provide Region V with a copy of To be provided by correspondence with NRR requesting relief February 3, 1982 from T. S. 6.8.1.1 for implementation of QA in Radiological Environmental Monitoring Program until 5% power or 7/1/82, whichever comes first.
- 2. Provide Region V with a writeup repre- To be provided by senting a systematic evaluation of sampling February 5, 1982 line compliance with ANSI 13.1 and other, applicable criteria (include discussion of intended use of SAI, heat tracing and condensation considerations) .
*3. Provide Region V with a writeup present- Enclosure (2) ing our position with respect to how we will meet tech spec requirements for continuous sampling of containment purge, etc; include a schedule.
*4. Provide Region V with environmental Enclosure (3) qualification documentation for containment ,
area high-range monitor cabling and i connection (confirm acceptable environment-al qualification of entire system; however, no additional submittal of information to the Region is required).
*5. Provide Region V with a writeup Enclosure (4) describing system calibration addressing: provides information (1) why vendor calibration is satisfactory for four monitors and has not been subsequently affected; and, (Control Room (2) the origin and acceptability of field Airborne; Contain-calibration sources, ment Airborne; Con-tainment & Purge Area; and, Plant Vent Stack Airborne Monitors). Informa-tion for additional five monitors (Hi-range in Containment; Radwaste. Discharge Line; Blowdown Neutralization Sump; Turbine Bldg. Sump; and, Steam Jet Air Ejector Monitors) to be provided February 4, 1982. Enclosure
- Must be addressed insofar as th (5) provides the basis t,ive monitors required for fuel for the schedule for loading in order to permit favorable input calibration of these by Region V to NRR regarding preparedness nine monitors.
for fuel loading. L_ .
Enclocuro - (I)
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ITEM STATUS
*6. Provide Region V with a schedule for Enclosure (6) the completion of all Task Force procedures.
- 7. Incorporate alarm set points, To be provided calibration curves and other information February 3, 1982 in the ODCM, or justify their exclusion. Provide Region V with a schedule of our plans in this regard.
*8. Provide Region V with a schedule for To be provided completion of training in the use of by February 4, 1982 process and effluent monitoring system.
- 9. Provide Region V with a summary of Enclosure (7) enhanced calibration which will be undertaken to ensure conformance to the tech specs; include a schedule.
- 10. Provide Region V with a writeup To be provided concerning the implementation of a QA by February 4, 1982 program for effluent monitoring, as required by Tech Spec 6.8.1.1.
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Enclosure 2 NRC Item 3 - GASEOUS EFFLUENT STREAM SAMPLING I. CCNTAINMENT. PURGE SAMPLING PRESENT PRCNISIONS:
. - Pedundant NMC gaseous radiation nonitors RE-7804-1 and RE-7807-2 (PSAR-11.5.2.1. 4. 5) presently nonitor contaiment airborne activity.
One monitor samples the containment atmosphere at approximately elevation 90' (same vicinity as the purge exhaust) and the other nonitor samples at approximately elevation 35'. Extensive mixing of the containment utnosphere by the normal HVAC units ensures that the sample locations are representative of the entire cx>ntain- ' ment atnosphere, and are therefore considered to be representative of the containment purge effluent stream. These nonitors provide the capability for Iodine, particulate and gas grab smpling. At present the particulate sample is of the moving filter paper type. The movina filter paper will be disabled (or alternatively a fixed filter mechanism will be installed) to provide interim fixed particulate sample capabilites per Technical Specification table 4.11-2.B. A correction factor will be applied to s mple analysis to account for sample line deposition. % is topic will be discussed as part of NRC Item 2. S m ple flow indication is provided on the nonitor. Based on the above, these nonitors ..ill be used to obtain composite samples e chn purge stream as required by Technical Specifications urt ne s ancements are complete. Future Enhancement
'Ihe capability to obtain continuous, cmposite particulate and iodinesamplesdirectlyfrhmthepurgestackwillbeprovided.
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1 Page 2 NRC Item 3 Future Enhancement (Cont'd)
. te system will be capable of obtaining representative smples over the full range of containment purge operation. % e system will also provide gas grab sample capabilities, indication of purge flow, and sample flow. Conceptual design of this system has begun. In the absence of confirmed procurement, engineering and construction schedules, operability of these modifications cannot be comitted to prior to.1-1-83. mre accurate operability '
dates will be available within 90 days. II CONDENSER EVACUATION SYSTEM te condenser evacuation system is monitored by two detector systems. First NMC monitor RE-7818 (FSAR 11.5.2.1.4.17) which is a noble gas monitor. Secondly by General Atcmic nonitor PE-7870-1 (FSAR 11.5.2.1.4.8) a wide range gas monitor which envelops the range of the NMC noble gas nonitor and also provides the capability for Iodine and fixed particulate smpling. We - l General Atanic monitor provides effluent flow indication. his capability will be available at Initial Criticality as specified in the pending Technical Specification revision table 4.11-2 (double asterick footnote) . %e nonitors described above will be used to supply composite samples of the condenser evaluation purge stream as required by Technical Specifications until.the the enhancements are complete. Future Enhancement Gas grab sapling capabilities are being added to the wide range gas nonitor (7870-1) .
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t Pag 6 3 .NRC Item 3 ' ' t Future Enhancement (Cont'd) Conceptual design has been completed and procurement, engineerirg, and construction are now being pursued. In the absence of con-
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firmed procurement, engineering, and construction schedules, operability cannot be cxmnitted to prior to 1-1-83. lere accurate comitment dates will be available within 90 days. III PLANP VENP STACK Present Provisions: NMC radiation monitior RE 7808 (FSAR 11.5.2.1.4.6) provides ' continuous nonitoring of the plant vent stacks as well as iodine, particulate and grab sample provisions. Presently the particulate sample is of the movina filter paper type. We noving filter paper will be disabled (or alternatively a fix filter mechanism will be installed) to provide interim fixed particulate sanple capabilities per Technical Specification table 4.11-2.C.2. A correction factor has been determined for sample line deposition and will be applied to the sample analysis.
- W is topic will be discussed as part of NRC Item 2. W e monitor also provides total sample flow indication. mis nonitor will be h utilized to supply the composite sanples required by Technical Specifications until the enhancements are complete.
General Atanic wide range gas monitors (2RE-7865-1 and 3RE-7865-1, FSAR 11.5.2.1.4.9) which envelops the gaseous range of RE-7808 will be available prior to exceeding 5% power (per Technical Specification table 3.3-10 double asterick footnote). We General Atomic monitors provide the capability for iodine and fixed particulate sampling.
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Enclosure 7 ? NRC Item 4 - IOCA QUALIFICATION OF HI-RANGE IN CONTAINMENT MNI'IORS
% e NRC during an inspection'on January 27, 1982, asked for clarification of the environmental qualification for the General Atomic high rame in-containment detector (2RE7820-1, 2RE7820-2) cable connections. .-_
% e detector cable connections examined by the inspectors have not yet had the vendor supplied heat shrink sleeves installed. These sleeves fit over the high voltaje and signal coaxial cable to detector connectors. Drawing S023-606-4-18 (GA Dwg. 0360-9019) show installation details of these sleeves. Document S023-606-4-46 (GA report E-254-960) " Test Report Class lE Design Qualification Testing of Analog High Range Radiation Monitor" documents the IDCA cualification testing for this sleeve-connector design.
To document the required installation of the appropriate sleeve ?CR 0665-J was written. The sleeves will be installed prior to required operability of these detectors (Mode 4 per Technical Specification ~ table 3.3-6.la and table 4.3-3.1.a.) . e *
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Enclosure 4 NRC Item 5: RADIATICN MONI'IORING SYSTEM DATA REVIEN An independent review of work on four of the priority one monitors (Control Roca Airborn, Containment Airborn, Containment Purge Area, and Plant Vent Stack) has been completed and data packages assembled. Review of the last priority one nonitor (In-Contairment Hi Range which is not reauired until Mode 4) and the three priority , two monitors which we will declare operable at Fuel Loading (Radwaste Discharge Line, Steam Generator Neutralization Sump and Turbine Plant Sump) utilizing startup data is in progress and is expected to be complete late this week. 'Ib date this independent review has confirmed that: I. Vendor calibrations were acceptably performed in accordance with procedures, II. Field work was performed acceptably and all repairs /nodifica-tions which could have invalidated results were suitably retested and, III. 'Ihe sources utilized in the field are relatable to the vendor calibration by virtue of the vendor certification of the ccmoarision of the field source to an NBS traceable source of the sane isotope and geometry and similar source strength. Attached is a sunnary of the independent review. findings and a description of the tests and calibrationc perforned on each of the monitors. L- I e
i RADIATIOJ MONI'IORI?G SYSTEMS CALIBRATIQJ & MAINTENANCE DATA R1, VIEW s ne data packages listed below contain information which describe the
- calibration and standardization methods used to place the following monitors in-service:
2RE 7808-A Plant Vent Stack - Iodine 2RE 7808-B Plant Vent Stack - Particulate 2RE 7808-C Plant Vent Stack - Gas 2RE 7807-A Containment Airborne - Iodine 2RE 7807-B Containment Airborne - Particulate 2RE 7807-C Containment Airborne - Gas 2/3RE 7825-A Control Ibcm Airborne Part/ Iodine - 2/3RE 7825-B Control Ibcn Airborne Gas. 2RE 7857 Containment Purge Area Monitor Each package contains the following infomation: (1) Vendor calibration data (2) Vendor calibration procedures (3) Start-up calibration data
. (4) Start-up calibration procedures (5) Calibration & Standardization source certificates - NBS Traceability (6) Maintenance Records of each Manitor Review of these documents and data packages confirms that each nonitor was calibrated by the vendor in accordance with the vendor's calibration procedure. % e start-up and test activities performed on-site were completed in accordance with approved procedures. In cach cace, the records demonstrate that the process monitors were calibrated in accordance with the calibration description contained in FSAR Section 11.5.2.1.5.2 and table 11.5-1 -
(enclosed as Appendix A) . l For example, the Containment Airborne Monitor (CA) site calibration data l indicates that for the gas channel (2RE-7807-2C), an NBS traceable Kr-85 source was used to calibrate that channel and that a Cs-137 source was i used to verify energy response. Ebr the iodine channel (2RE-7807-2A) l an NBS traceable Ba-133 source was used to calibrate the single channel analyzer and a Cs-137 source was used to verify enemy response. Simi-larly, for the particulate channel (2RE-7807-2B) an NBS traceable Co-60 source was used for calibration and a Cs-137 source was used to verify ' eneg y response. 'Ihe sources used during the site calibrations are the sane isotopes used by the vendor, and are related through NBS traceable certificates. l ' l . - e . n. w - h:a. . i . . . .. . , ' . m. i.:.:
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9 For each of the Fonitors required to meet the fuel-load requirement, a review as described above was performed with similar findings and results. Based on these reviews and findings it is concluded that each of the referenced nonitors was calibrated in accordance with the description contained in the FSAR. Further, it is concluded that these calibration tests were performed using generally accepted methods and procedures comnon to industry practice. However, the calibrations do not meet the requirements of Regulatory Guide 4.15, 4 Rev. 1, which reauires an enhanced calibration and quality assurance program. 'Ihe new calibration procedures being developed by the SONGS Radiation Monitorina Task Force address these new requirements and will be implemented usina a phased approach described elsewhere. The process and area radiation monitoring system calibration performed on-site have been reviewed by cualified professionals and have been ., determined to be adeauate and consistant with the calibration require-ments of the FSAR. Maintenance and Calibration History With respect to the cuestions raised concerning calibrations not being performed following detector maintenance or other activities which could obviate a previous calibration, a review of the maintenance manacement records (MTS) indicates that the question is specious. A detailed review of the MrS records associated with each nonitor , channel and the Start-Up Work Permits (SWP) associated with each activity reveal that calibrations of the appropriate channel were performed followina any maintenance or repair activity that may affect the validity of a previous calibration. A summary maintenance history for these monitors is attached. l - t l
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SUMMARY
OF PRE-OPERATIONAL TESTING PERFORMED AT SONGS UNITS 2 AND 3 ON MC PIAVf VENT STACK AIRBORNE (PVSA) RADIATION MONI'IORING SYSTFE (RT 7808) Pre-operational testing of the MC PVSA Radiation & nitoring System was performed in accordance rith Section 8.9 of procedure 2PE-340-02 titled " Process Radiation &nitoring System". The test utilized system self-testing features, switch operations, and simulated detector inputs (pulse generator) to functionally verify indications, alarm, and protective relay operation. Quantietive as well as baseline data was obtained and recorded for such parane;.or: as alarm setpoints, detector high voltage, check source , reslunse, and sample line flow rates. Additionally, system grab sample functions were demonstrated to operate properly, and sanple pt.rnp low flow interlocks were tested. er 4 k r M 1 , eh *6%
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OF PRE-OPERATIONAL TESTING PERFOPf4ED AT SONGS UNIT 2 ON EC COf7I'ROL ROCH AIRBORNE
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RADIATION MONITORING SYSTEM (RT 7825-2) a Pre-operational testing of the MC Control Rxn Airborne Radiation Penitoring System was performed in accordance with Section 8.14 of procedure 2PE-340-02 titled " Process Radiation tbnitoring System".
'Ite test utilized system self-testing features, switch operations, and simulated detector inputs (pulse generator) to functionally verify indi-sation, alarm, and protective relay operation.
Quantitative as well as baseline data was obtained and recorded for such paraneters as alarm setpoints, detector high voltage, check source . response, and sample line flow rates. Additionally, system grab sample functions were denonstrated to operate properly, and sanple ptrap low flow interlocks were tested. 4 e n
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OF PREREQUISITE TESTING PERFOPFED AT SONGS UNIT 2 ON FNC COU1 POL ROCH AIRBORNE RADIATION MONITORING SYSTEM (RT 7825-2)
%e pre-requisite testing of the SONGS Unit 2 NMC Control Ibom Airborne Radiation Monitoring System consisted of the performance of ten indi-vidual " Generic Tbsts" (GT's) . %ese GT's consisted of flow instru-mentation, check source and filter paper advance drive circuits, modular counting rate meter, power supply, and analog and digital output circuit calibrations / functional verifications.
Additionally, instrument and control loop verifications and Isotopic Standardizations ware performed with these test frocedures. W e Isotopic tests were performed on both of the system channea (gaseous and iodine / . particulate) utilizing NBS traceable sources, plateau and spectrun curves, and unique data sheets for each type detector. . Enclosed are copies of each test procedure and the respective cmpleted data sheets. The followirg is a description of the testing performed with each of the ten Generic Test Procedures: GT-300-199 - Functional test of the system DURANT Program Counter, a sample flow indicating device. %is procecure denenstrated that the instrument properly monitored and tabulated simulated input pulses with resolution accuracy. GT-300-308 - Calibration of the system DhYER Photobelic Differential Pressure Switch / Gauge. This instruaent provides visual sample flow indication, as well as switch contact outputs for both high and low flow conditions. We procedure calibrated the instrment to manufacturer's specified accuracy of + 2% of range by utilizing a standardized variable pressure source and verifying a minimun of five points in the total rarge. ~ Additionally, switch contacts were verified to change state as high and low setpoints were exceeded with increasing and decreasing pressure, respectively. GP-300-297 - Setting all system alarms.
%is procedure initially set high radiation and instrument l fail alarms with the applicable potentiometers and meter l indication. Alarms were then functionally verified using i a simulated detector signal input (i.e., pulse generator)
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GT-300-255 - Calibration of System signal conditioners / isolators. We test adjusted the analog outputs available for computer inputs (either millianpere or DC voltage signals) . Wis was acconplished by sinulating an input from the radiation nonitor system to the signal conditioners / isolators and adjusting these canponents for proper outputs end of loop conponents. Finally, a five point calibration check of these instruments was performed over full range. GT-300-309 - Ebnctional test of the system check source and paper advance circuits. W e procedure demonstrated that check sources could be exposed to their respective detectors and retracted with control voltage applied to proper circuit terminals. Additionally, paper advance circuitry was verified to operate properly in all selectable speeds, rapid paper advance node was performed, and paper take-up real was observed to function correctly. Finally, all detector dambers were cleaned, silicone grease applied to detector 0-rings, and mineral oil applied to any check source me&anism and/or paper advance nechanism noving parts as needed. GT-300-321 - Electronic test and calibration of the system Modular Counting Rate Meter. This procedure calibrated system analysis, indication, computer analog outputs, and alarm functions by sinulating varying detector inputs utilizing a pulse generator and frequency counter. Numerous circuit voltages were adjusted and verified, indicating neter calibrated, and analog outputs set with multipoint input signals throughout system range. Wis was followed by a six or seven point calibration deck of local indicator, and analog computer output, again using electronic pulses as simulated detector input. Self alarns were functionally verified to properly trip and reset as specified values were eymeded and then decreased / increased as applicable. Miscellanecus voltages were checked, and high voltage output was aljusted to an accuracy of + 5%. Finally, an input node switch line-up was performed as specified on procedure Exhibit "D". G'P-300 Instrumentation and Control Icop Functional Verification. This procedure initially verifies all caTponents of a given loop have been satisfactorily calibrated, wiring termina-tions are tight and in accordance with applicable drawings, permanent loop power is available at the proper voltage arti frequency, and all plastic screws and washers have been removed fran signal wiring. Since there are actually two loops (gaseous, and iodine / particulate) associated with this system, the test was performed twice - once for each loop.
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In ead case, the detector signal input was sinulated uti-lizing a pulse generator, verifying five points through-out the range. We system indicators and analog conputer inputs were verified at ead point to be within + 5% of linear full span (specified system accuracy). Additionally, local and remote annunciators were verified at required alarm setpoints and the plant conputer alarm was denonstrated to function properly at it's respective settnint. Finally, handswitch positions at panel 2/3L104 (where the nonitors are located) and control room panel ' CR60 were operated and the plant conputer was verified to indicate switch status danges. GT- 300-327 - Gaseous Monitor Isotopic StaMardization (calibration) . This test developed and plotted a detector plateau curve utilizing the installed check source and increasing high - voltage inputs in 50 VDC increments from a mininum baseline. Optimum detector high voltage was then determined utiliziry the plateau's linear region and adjusted accordingly. %en baseline background and check source readings were obtained and recorded, followed by exposing the detector to a solid Cs 137 source. For additional baseline data ard geomtric considerations (ie., check source geanetry with respect to detector nuy very slightly with time due to cams in associated nedanical housing, where the solid Cs 137 sour will be placed in same proximity to detector in subsequent calibrations and thus can be used as an additional, more dependable system check). An NBS traceable gaseous isotope was then bled into detector well and the nonitor was allowed to stabilize. A counts / min averaged reading was calculated over a mininum 5 minute period and this data was then used to determine percent yield and detector tolerance. After purgirg the detector well, all testing was repeated for the system high range gas . detector nonitor. GT-300-330 - Iodine Monitor Isotopic Standardization (calibration) . ' W is procedure utilized the system Ba 133 check sour in j conjunction with varying detector high voltage inputs to plot and outline of the detector response. Optimum high - voltage setting was then determined and adjusted, and baseline data recorded. Additionally, a standardized BA 133 source was used to calculate percent yield and detector tolerance followed by a slight high voltage adjustment due to the small difference in energy levels between the BA 133 ard I 131. Background settings were accanplished with a Cs 137 or CO 60 source, and finally, a new iodine cartridge was installed.'
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SUM %RY OF PREREQUISITE TESTItG PERFOINED AT S2GS UNITS 2 AND 3 INC PIR4T VENT SPACK AIRIDENE (PVSA) RADIATICt1 MONITORI?G SYSTEM (RT 7808)
%e pre-requisite testing of the SotGS Units 2 & 3 INC PVSA Radiation Monitoring System consisted of the performance of ten irdividual test procedures, termed " Generic Tests", or "GT's". Wese GT's consisted of flow instrumentation, check source and filter paper advance drive circuits, mdalar counting rate mter, pcwer supply, and analog and digital output circuit calibrations / functional verifications.
Additionally, instrumnt and control loop verifications and Isotopic Stardardizations were performed with these test procedures. W e Isotopic tests were performed on all three system channels (gaseous, particulate, and iodine) utilizing NBS traceable sources, plateau and spectrum curves, ~ and unique data sheets for each type detector. Note that the GT's also require specific test 'equipwnt, specify accur-acies, proper instrumnt location and identification verifications, and system / component restoration. . Enclosed are mpies of each test procedure and the respective cm:pleted data sheets. The following is a description of the testing performed with each of the ten Generic Test Procedures: GT-300-199 - Functional test of the system DURANT Program Counter, a sauple flow indicating device. This procedure demonstrated that the instrumnt properly monitored and tabulated simulated input pulses with resolution accuracy. GT-300-308 - Calibration of the system DNYER Photohelic Differential Pressure Switch / Gauge. W is instrument provides visual sample - flow indication, as well as switch contact outputs for both high and low ficw conditions. The procedure calibrated the j instrumnt to manufacturer's specified accuracy of + 2% of j range by utilizing a standardized variable pressure source and , verifying a minimum of five points in the total range. Additionally, switch mntacts were verified to change state as high and low setpoints were exceeded with increasing and decreasing pressure, respectively. l GT-300-297 - Setting all' system alarms. This procedure initially set high radiation and instrument j fail alarms with the applicable potenticmeters and eter indication. Alarms were then functionally verified using a simlated detector signal input (i.e. , pulse generator) ard front panel test switches. l u r
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GT-300-309 Functional test of the syst s check source and paper a3vance circuits. We procedure de::enstrated that check sour s could be exposed to their respective detectors and retracted with control voltage applied to proper circuit terminals.
. Additionally, paper advance circuitry was verified to operate properly in all selectable speeds, rapid paper advance node was performed, and paper take-up reel was observed to function correctly. Finally, all detector chambers were cleaned, silicone grease applied to detector 0-rings, and mineral oil applial to any check source mechanism and/or paper advance mechanism noving parts as needed.
GT-300-321 - Electronic test and calibration of the system Modular Counting Rate Meter. This procedure calibrated syst s analysis, . indication, conputer analog outputs, and alarm functions by simulating varying detector inputs utilizing a pulse generator ~ and frequency counter. Numerous circuit voltages were adjusted and verified, indicating meter calibrated, and analog outputs set with multipoint input signals throughout system range. This was followed by a six or seven point calibration check of local in3icator, and analog computer output, again using electronic pulses as simulated detector input. Self alarms were functionally verified to properly trip and reset as specified values were exceeded and then decreased / increased as applicable. Miscellaneous voltages were checked, and high voltage output was a3 justed to an accuracy of i 5%. Finally, an input node switch line-up was performed as specified on procedure Exhibit "D". GT-300 Instrumentation and Control Icop Functional Verification. This procedure initially verifies all components of a given loop have been satisfactorily calibrated, wiring termina-tions are tight and in accordance with applicable drawings, permanent loop power is available at the proper voltage ~ an3 frequency, and all plastic screws and washers have been renoved frcm signal wiring. Since there -are actually three loops (gaseous, particulate, and iodine) associated with this systs, the test was performed three times - once for each loop. 7 ~ In each case, the detector signal input was sinulated uti-lizing a pulse generator, verifying five Irints through-out the range. We systs indicators and analog conputer inputs were verified at each point to be within i 5% of linear full span (specified system accuracy). Additionally, local and renote annunciators were verified at required alarm setpoints and the plant conputer alarm was demonstrated to function properly at it's respective setpoint. Finally, han3 switch positions at panel 2/3L104 (where the nonitors are located) and control rom panel CR60 wre operated and the plant computer was verified to irdicate switch status changes. r- .,- . .f i ^ E ". l _ wa.
GT-300-327 - Gaseous Mcnitor Isotopic Standardization (calibration) . This test developed and plotted a detector plateau curve . utilizing the instr.11ed check source and increasing high voltage inputs in 50 VDC increments from a mininum baseline. Opti:ntn detector high voltage was then determined utilizing the plateau's linear region and adjusted accordingly. %en baseline background and check source readings were obtained and recorded, followed by exposing the detector to a solid Cs 137 source. For additional baseline data and gemetric considerations (ie. , check source geometry with respect to detector may very slightly with time due to cams in associatal me&anical housing, where the solid Cs 137 source will be placed in same proximity to detector in subsegaent calibrations and thus can be used as an additional, more dependable system deck) . An NBS traceable gasecus isotope was then bled into detector well and the nonitor was allowed to stabilize. A - counts / min averaged reading was calculated over a mininum 5 minute period and this data was then used to determine. percent yield and detector tolerance. After purging the detector well, all testing was repeated for the system high range gas detector nonitor. GT-300-329 - Particulate Monitor Isotopic Standardization (calibration) ..
%is procedure utilized nethods similar to those described in GT-300-327 above. Check source readings were again used to determine high voltage plateau curves, Cs 137 and Co 60 standardized sources were used to determine percent yield and detector tolerances, and baseline check source and bad-ground readings were obtained and documented.
GT-300-330 - Iodine Monitor Isotopic Standardization (calibration) . This procedure utilized the systen Ba 133 check source in conjunction with varying detector high voltage inputs to - plot and outline of the detector response. Optinum high voltage setting was then determined and adjusted, and baseline data recorded. Additionally, a standardized BA 133 source was used to calculate percent yield and detector tolerance followed by a slight high voltage adjustment due to the small difference in energy levels between the BA 133 and I 131. Badground settings were accanplished with a Cs 137 or CO 60 source, and finally, a new iodine cartridge was installed. GT-300 Calibration of the Westronics recorder. The procedure involves setting up the recorder for calibration / operation by initially applying ink to the printhead, loading d art paper, and . connecting test equignent (a Nllivolt calibration source) to the proper terminals. We servo driven printing medanism is then decked for me&anical freedan of movement and scale alignment, and this is followed by zero and span range adjust-ments with the desired signal inputs. Finally, five points are calibration checked over full range with bath increasing and decreasing signal inputs. g w g g
CXNTAINMENT AIRBORNE AND PURGE AREA MONITOR RE-7807 and RE-7857
'Preoperational and Prerequisite testing of the Containment Airborne Radiation Monitor (RE-7807) and Containment Purge Area Radiation Monitor (RE-7857) similar to that sumarized here has been performed. Copies of the tests and resultant data are available at the jobsite.
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tirnosure a Basis for Calibration Schedule for Nine Monitors a!., Discussed with NRR Janun'r 28, 1982 I - - SUPNARY 'OF SCHEDULE REASON; SCHEDULE RELIEF MONI'IOR ! STA'1US RELIEF REQUESTED IS RM)UIRED Priority I. a) Control Ibcm Presently at least Accept. calibrations performed Schedule relief is required Airborn monitor one channel of each during the startup progre in in order to provide sufficient RE-7824/7825 nonitor has been compliance with FSAR section time for enhanced calibration b) Contairrnent calibrated (Per 11.5.2.1.5.2 in place of the of these nonitors to be per-
} . Airborn nonitor FSAR 11.5.2.1.5.2) CHANNEL CALIBRATION requirements formed in a timely manner
- f RE-7804/7807 and has empleted of the applicable tech. spec. consistant with the plant i; c) Containment Purge preoperational section prior to intial power evolutions during initial Area Monitor testing per FSAR increase above 5% Rated 'Ihermal startup.
RE-7856/7857 chapter 14 (Note Power
; j. d) Plant Vent Stack Technical Specifica-7 Airborn Pbnitor tions tables 3.3-6 and RE-7808 3.3-12 require only one channel of each
, of these monitors (a-d) 4i e) Hi-Rance in to be operable). As above. Note: Operability Containment is not required until Mode 4 Jt Monitor per tech. spec. table 3.3-6.
!f RE-7820-1/ ,, 7820-2 ll Priority II. a) Radwaste Dis- Presently each 1. Accept calibrations per- Schedu g relief is required l charge Line ronitor has been formed during the startup to alldk available resources
', Monitor RE-7813 calibrated (per FSAR progra in compliance with to be concentrated on per-b) Blowdown Neutra- 31.5.2.1.5.2) and FSAR section 11.5.2.1.5.2 forming the upgrade progran lization Sump has been preopera- and functional testing on the highest priority .! Monitor RE-7817 tinally tested per performed in accordance with monitors, therebu cmpleting c) Soine Building PSAR chapter 14 FSAR section 14.2.12.22 in the enhanced calibrations ) Sump Monitor place of the OIANNEL CALI- at the earliest date achiev-4j RE-7821 BRATION and CHANNEL FUNC- able ! TIONAL test requirements of the applicable tables -
until power increase above 5% Rated Thermal Power
- 2. Defer repetition of sub-sequent OIANNEL EUNCTIONAL
'IESTS until 30 days after initial criticality.
j d) Steam Jet Air Not presently operable Not required until Initial 4 ,; Ejector Monitor , Criticality
- RE-7818 A&B
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JUSTIFICATION FOR . SOIEDULE RELIEF W e combination of vendar :* and field calibrations (per FSAR 11.5.2.1.5.2) are the deJign basis of the plant.
%ese calibrations provide adequate confidence that i, .
th2 nonitors are properly - calibrated given the low -
"j probability for release prior to exceeding 5% of Rated ,
Thermal Power. Periodic sur- . ; veillances (OIANNEL FUNCTIONAL ; TESTS, GIANNEL 01ECKS, AND SOURCE QiECKS) performed in accordance with approved ; Station procedures provide ! additional confidence that t thdse monitors will perform '! . as! required in the unlikely ,! ev!nt of an unplanned release. '
< o Wh combination of vendor and field calibrations (per '
FSAR 11.5.2.1.5.2) and pre-operational test results (per .! FSAR 14.2.12.22) provides !i adequate confidence that the ! monitors are properly cali- .
.brated and operable. Prior :* . 'to; Initial Criticality no -!
fission product inventory b; l[ exists in the plant and there .!i o fore to these through possibility of release paths exists. ~ Q;l Between Initial Criticality - and 5% Rated %ermal Power Y[' is very the small and the prob-accumulated radwaste volumeh@ ability for an unplanned [ release is extranely low. D Prpor to Initial Criticality , no possibility of release via tha SJAE exists h' i: .
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. ENCLOSURE 7 NRC Item 9 - RADIATICN MONI'IOR ENHANCED CALIBRATION PROGRAM
%e radiation monitioring progran enhancement has been formulated to provide San Onofre Units 2&3 with state of the art calibration techniques beyond currerit industry practice and includes compliance with Ra ulatory Guide 4.15, Revision 1. All sources will meet the NBS traceability requirements of Regulatory Guide 4.15 and the method of compliance (Note 2 of Regulatory Guide 4.15) will be documented. %e isotopic source strengths and forms will be based ,
on the detector type and range as well as considerations for main-taining offsite releases and personnel exposures as low as is reasonably achievable. We isotopic calibrations shall be final verifications of detector response. t ese verifications are preceded by electronic loop, linearity, pulsed light emitting diode and radiation source testing as applicable. %e isotopic calibrations are performed with the detector installed in its normal operating configuration.
%e following isotopes will be used as part of the radiation monitor-ing enhanced calibration program. W e following concepts were used i in developing the calibration enhancement progran.
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- 1. NMC Gaseous Detectors (Containment Airborne [CA], Plant Vent Stack Airborne [PVSA], Radwaste Disposal Area Vent [RDAV),.
Fuel Handling Area Vent [MIAV), Control Bocm Airborne [CRA]) .
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- a. Gaseous Beta Scintillation Detectors -
.. i. Kr-85 gas sources:
- a. Approximate concentration of 5x10 -5 7 (yielding around 1000 CPM),
- b. Approximate concentration of 1x10 -3 pci/cc (yielding around 36,000 CPM) .
ii. Xe-133 gas source: Approximate concentration of 1x10 -4 *
- a. pel/cc (yielding around 10,000 CPM) .
- b. M]ving Particulate Filter Beta Scintillation Detectors * ,(CA, PVSA)
- 1. Cl-36 sources:
- a. Approximate activity of 4.4x10 -3 7ci/cc (yielding around 3,000 CPM),
- b. Approximate activity of 5x10 -2 pci/cc (yielding around 30,000 CPM).
ii. Sr-90 source: -
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- a. Approximate activity of 1x10-2 j/ci/cc (yielding around 4,200 CPM).
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geometry and take proper account of source / filter paper self-absorption. t
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- e. Gaseous Detectors - (Waste Gas Header [NGI), Condensor Air Ejector Gas [CAEX3])
- 1. Iow Rame - (Beta Scintillation)
- a. Use of two Kr-85 gas sources:
- i. Approximate concentration of SX10-5 gci/cc (yielding around 1000 CPM),
ii. Approximate concentration of lx10 yci/cc (yielding around 36,000 CPM). .
- b. Xe-133 gas source:
Approximate concentration of 1X10-4 i. fci/cc (yielding around 10,000 CPM) . ii. High Range *
- a. Xe-133 gas sources:
- i. Approximate concentration of 1x10 -2 pci/cc.
ii. Approximate concentration of lx10 -1 gci/cc.
- b. Kr-85 gas source:
- 1. Approximate concentration of lx10 -1 pci/cc.
*CAFJ monitor presently being changed frm beta scintillation detector to NaI. Modifications to the NGH monitor are being mnsidered.
l 2. NMC Liquid Detectors (Neutralization Sump Discharge [NSD], Cmponent Cooling Water [CCW], Radwaste Discharge Line [RDL], Turbine Plant Area Sump [TPAS),
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- a. Cs-137. sources #:
- i. Approximate concentration of 10 -4 pci/cc 4
(yielding around 2x10 CPM), ii. Approximate concentration of 5x10 -6 pei/cc (yielding around 10 3CPM).
- b. Co-60 source 4: ,
- i. Approximate concentration of 10 -4 j ci/cc ,
(vieldino around 5x10 CPM).
- c. Ba-133 source #:
- i. Approximate concentration of 10 -4 o
/ ci/cc
#All sources are a 3 liter liquid canister which duplicate INC detector qeometry.
- 3. Safety Related Containment Purge Area Manitors (RIT-7856-1, RIT-7857-2)
- a. Cs-137 sources capable of producing a radiation field 4
l for each decade over the range of 0.1 to 10 mR/hr. ;" ' l t
- b. Co-60 source capable of producire a radiation field of approximately 100 mR/hr at 3 feet.
- 4. Dnergency Area Radiation Monitors (RI-7858-1, RI-7859-2, RI-78'60-3) 1 I
- a. Cs-137 sources capable of producing a radiation field M :..:- ..v .. -
j~'r.'. for each decade over the range of 0.1 to 104 mR/hr.
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, b. 6 60 source capable of producing a radiation field of approximately 100 mR/hr at 3 feet.
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- 5. tNC tbn-Safety Related Area Monitors
.. (2/3RI-7841, 2/3RI-7842, 2/3RI-7843, 2/3RI-7844, RI-7845, RI-7847, RI-7848, RI-7850, 2/3 RI-7851, 2/3RI-7852, 2/3RI-7853, 2/3RI-7854)
- a. Cs-137 sources capable of producing a radiation field for each decade over the range of 0.1 to 104 @.
- b. 00-60 source capable of producing a radiation field of approximately 100 mR/hr at 3 feet.
- 6. Wide Range Gas Monitors (RE-7870-1, RE-7865-1)
- a. Iow Range (Beta) 'Ib supplement the energy response data supplied by General Atomic two Cl-36 cources will be used.
- b. Mid aM liigh Range (Gamma Scintillation) - Mditional detector energy response data is being developed by General Atcznic. At least one Cs-137 source will be used. Mditional source (s) are being developed in conjunction with General Atomic.
- 7. Main Steam Line Monitors (RE-7874Al, RE-7875B1, RE-7874Al, RE-7875B1)
- a. Iow Range - General Atomic RT-10 calibrator with Cs-137 source yielding dose rates of approximately 29 mR/hr and 1 R/hr.
! b. High Rarne - General Atomic RT-10 calibrator with Cs-137 source yielding dose rate of approximately 1 R/hr.
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- 8. Iligh Rame In- Containment Detector (RE-7820-1, RE-7820-2)
. a. General Atomic RT-ll calibrator with Cs-137 source yieldirg dose rates of approximately 3 R/hr aM 10 R/hr.
- 9. Normal Sanple Line Monitor (2/3BE-7838, 2/3RE-7839)
- a. Low Range - General Atomic RP-10 calibrator with Cs-137 source yieldirn dose rates of approximately 29 mR/hr aM 1 R/hr.
- b. Iligh Range - General Atanic Irr-10 calibrator with Cs-137 source
- e yieldirn dose rate of approximately 1 R/hr.
- 10. Post Accident Sample System Area Monitor (2/3RE-7884)
- a. General Atomic RP-10 calibrator with Cs-137 source yielding dose rates of approximately 29 mR/nr and 1 R/hr.
- 11. Steam Generator Blowdown Radiation Monitor (RE-6753 and RE-6759)
- a. Task force is reviewing detector geanetry and design to determine isotopic form and intensities to be used. ' Itis is expected to be calibrated in a manner similar to the NMC licuid monitors.
- 12. Intdown Line Process Radiation Monitor (RE-0202)
- a. Task force is reviewing existing vendor supplied sources to determine if additional strengths or energies are required.
Vendor supplied sources:
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- 1. 00-60 is liquid form activity approximately 2x10 ~1 ci/cc
-2
- 11. Ba-133 is liquid form, activity approximately 2x10 ci/cc
-2 iii . Cs-137 in liquid form, activity approximately 2x10 ci/cc iv. Ra-226 solid source, capable of establishing 1 mR/hr and 5 mR/hr field.
A schedule for the radiation monitoring enhancement program has been generated, and is available upon request. 'Ihis schedule pertains to all radiation nonitors (including those not in the Technical Specifications) and indicates that all enhancement work should be completed in approximately six nonths. A sumary schedule can be transmitted upon request. e S l . i g
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DESIGNATED ORIGINAL I Co2tified By 0P Southern California Edison Compan? P. O. B O X 8 00 56 2 2 44 W ALNUT GROVE AVENUE A05EMEAD. C ALIFORNI A 9 9770
" A *^mn February 3, 1982 " ' " " " ' """ :. ;:." .':"a"::::"' " " ' " " " '
Director, Of fice of Nuclear Reactor Regulation Attention: Mr. Frank Miraglia, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatery Commission Washington, D.C. 20565 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 On January 28, 1982, a meeting was held at the NRC offises in Bethesda, Maryland. The purpose of the meeting was to discuss the implementation program for radiation monitors for San Onofre Nuclear Generating Station, Units 2 and 3. The implenertation prngram has two main objectives. The first is to provide radiation monitors for which the calibration is consistent with the latest state of the art criteria on the most expeditious schedule possible. The second objective is to ensure consistency between the schedule for bringing the radiation monitors into full compliance with the technical specifications and the stage in the initial plant startup at which they are functionally required. To achieve these objectives we have developed a phased approach. In accordance with agreements reached in the meeting, enclosed for your use are seven (7) copies (NRC Mail Code B028) of the following material: Enclosure 1: Specific Technical Specification pages changed to provide schedule relief requested to allow suf ficient time for enhanced calibration of radiation monitors. Enclosure 2: Tabular presentation summarizing for each radiation monitor, the schedule relief requested, the reason the schedule relief is required and justification for the schedule relief. **~ og
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Enclosure 3: Justification for schedule relief on installation of proportional samplers. i- : 'i
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g t Mr. Frank Miraglia Enclosure 4: Discussion of present containment purge sampling provisions. If you have any questions concerning these matters, please call me. Very truly yours,
- 57. f f> w , , e Ir P B Enclosures cc: . F. J. Wenslawski-Region V 1
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' ENCLOSURE 1 Technical Specification Changes l
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i ( h Y l O m TABLE 4.3.-2 (Continued) 9 Ym ' i Q x E ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREE NTS
'j CHANNEL MDDES FOR tRilCH '
[ CHANNEL : CHANNEL FUNCT10NAL SURVElLLANCE 5 d CHECK CAllBRATION TEST IS REQUIRED ; FUNCTIONAL UNIT m l
- 7. LDSS OF POWER (LOV) '
- a. 4.16 kW Emergency Bus l Undervoltage (Loss of -
6 Voltage and Degraded 1, 2, 3, 4 i Voltage) 5 j R R
- 8. EMERGENCY FEEDWATER (EFAS) 1, 2, 3 i a. Manual (Trip Buttons) N.A. . N.A. R ,
- b. SG Level (A/8)-Low and , i
' 1, 2, 3 l AP (A/B) - Nigh . S R M
- c. SG Level (A/B) - Low and No 1, 2, 3
- Pressure - Low Trip (A/8) S R M
- d. Automatic Actuation Logic M.A. N.A. M(1)(3),SA(4) 1, 2, 3 l
$ 9. Control Room Isolation (CRIS)
- a. Manual CRIS (Trip Buttons) N.A.
N.A. R N.A. l w N.A. - L, b. Manual SIAS (Trip Buttons) N.A. , M.A. R N c. Airborne Radiation All
- 1. Particulate / lodine S R 6) M l l
- 11. Gaseous S R6 M A11 N.r3 1 -
All ,C 3 ! d. Automatic Actuation Logic N.A. .. , R(3) l c3
-v1
- 10. Toxic Gas Isolation (TGIS) N.A. C*
- a. Manual (Trip Buttons) N.A. M.A. R 5 R M , All 33 g
- b. Chlorine - liigh '
- c.
- Ammonia - High S R M All LQ
- d. Butane /Prepane - Nigh 5 R M All ig .
- e. Carbon Oloxide - High S R M All u i
- f. Automatic Actuation Logic N.A. N.A. R (3) All p .
;3 .
D T1 I - e: . % g? a : g
~
Q 4 .
TABLE'4.3-2 (Continued) C ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS 'S MODES FOR WHICil 4 CHANNEL E CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE
'. FUNCTIONAL UNIT CHECK CALIBRATION TEST IS REQUIRED
,= .
- Fuel Handling Isolation (FHIS)-
11.
'3
- a. Manual (Trip Buttons) N.A. N.A. R N.A. -
- b. Airborne Radiation *
- 1. Gaseous S R H .
ii. Particulate / Iodine 5 R M
- c. Automatic Actuation Logic N.A. N.A. R(3)
- 12. Containment Purge Isolation (CPIS) -
i a. Manual (Trip Buttons) N.A. N.A. R N.A. , b. Airborne Radiation
- i. Gaseous (2) (2)[(, !
(2) 'All . ii. Particulate (2) (2yj (2) All ' iii. Iodine (2) (2[c, (2) All
? c. Containment Area Radiation -
d (Gamma) S R (G) M 6
- d. Automatic Actuation Logic N.A. .. R (3) All TABLE NOTATION (1) Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS.
- C3 (2) In accordance with Table 4.3-9 surveillance requirements for these instrument channels.
, Q (3) Testing of Automatic Actuation Logic shall include energization/de-energization of each initiation i '*
relay and verification of the OPERABILITY of each initiation relay. ! ~1 (4) A subgroup relay test shall be performed which shall include the energization/de energization of each ' subgroup relay and verification of the OPERABILITY of each subgroup relay. - a \ (5) Actuated equipment only; does not result in CIAS. - 3 o ~- m * .. (y spnt kQ FS 2 kk Il.G.2M.'-) nrwad vo. M wy foyM^l i
$ cdcpMe_. A du: 4. L.in-AL $4hN H Lt (All6fATlod U *fFM*')___
t'.*5%f5
% _ i
TABLE 3.3-6 z ' RADIATION MONITORING ALARM INSTRUMENTATION S 4 MINIMUM CHANNELS AFri..ABLE ALARM- MEASUREMENT z INSTRUMENT OPERABLE MODES SETPOINT RANGE ACTIOK
" 1. Area Monitors *
- a. Containment - High 2 1,2,3 2 R/hr 1-108 R/hr 18 -
Range 4 JNP R r 19 - 2
- b. Containment - Pu'rge 1 1,2,3,4 < 325 mR/hr 10 1-105 mR/hr 19 Isolation 6 7 (a) ,.
1/line 1 mR/hr (low);
~
1F# c. Main Steam Line 1,2,3 10 1-104 mR/hr; 18 1 R/hr (high) . t!"' 4 1 mR/hr (low); 19 . 1 R/hr (high) g> . y 2. Process Monitors
- a. Fuel Storage Pool Airborne
- i. Gaseous 1 * # 101 -107 cpm (d) ii. Particulate / Iodine 1 * # 101 -107. cpm (d)
- b. Containment Airborne .
4
- i. Gaseous -
1 All Per ODCM 101 -107 cpm (a)(b)(c) c[asEj ti. Particulate .1 All Per ODCM 101 -107 cpm (a)(b)(c) iii. Iodine 1 All Per ODCM 101 -107 cpm (a)(c) ;E,I] t
- c. Control Room Airborne !
'I'
- i. Particulate / Iodine 1 All # 101 -107 cpm (e) ' 1
,~,, ii. Gaseous l' All # 101 -107 cpm (e) l' ,'
]
- 5 i
C3 a .! . >. SS I' I.
l TABLF 3.3-6 (Continued)
? RADIATION MONITORING ALARM INSTRUMENTATION
?
- MINIMUM 3 CHANNELS APPLICABLE ALARM MEASUREMENT
, j INSTRUMENT OPERABLE MODES SETPOINT RANGE ACTION
- 3. Noble Gas Monitors Plant Vent Stack 1 All Per ODCM 101 - 107 cpm 19, (c) -
1 .
**b. Condenser Evacuation ! System 1 All Per DDCM 101 -
107 cpm 19, (c). 4
's .
12 1 I ,, 5 3 i i5 l i
.. I,
> t- :
lI
. I
. I i !. !
i m ! tm : ; I o !L; , 1 l , =%. t LO g _. t
- n. . . .
, 1--- ,
,j
; A!'t t ....i t( .- a; l.j.' ; -.
* *ly l
AC110N $1AllitfN15 ACTION 18 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE ai .e , comply with the ACTION requirements of Specific tion 3.3.3.6. (O ACTION 19 - With the number of OP ABLE C nnels less than the Minimum Channels OPERABLE re iremen , restore .he inoperable Channel (s) to OPERABLE status wi hi 7 ays, or in at least HOT STANDBY within the next 6 hour in east HOT SHUTOOWN within the follow'eng 6 hours and in OLD SHUTDOWN within the subsequent 24 hours,
#In accordance with Engineered Safety feature trip value specified by Table 3.3-4.
With irradiated fuel in the storage pool.
*A To be operational prior to initial criticality.
(a)ln accordance with Table 3.3 ACTION 17. (D)ln accordance with Table 3.3 ACTION 17a. (c)ln accordance with Ta.ble 3.3 ACTION 17b. (d)In accordance with Table 3.3 ACTION 16. h ble - ACTION - gg)fvSw q.re w.#r ra+g %,;nibAl chane.l M&Ah,ok i on thJ ve.ns. thc. L E.nif,d';' conMnwe.L owak'on h ne l Aqtod sSs.nt Nor\4 , s is Ah A-TE8 0 f 56; SAN ONOFRE-UNIT 2 3/4 3-37
--ee.-e,e
' ~~
TABLE.4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL MODES FOR WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE INSTRUMENT CHECK CALIBRATION TEST IS REQUIRED
- 1. Area Monitors
- a. Containment - High Range 5 R (s) M 1,2,3,4
- b. Containment - Purge Isolation .S ,
(1 M 1, 2, 3, 4
# # # 6
**c. Main Steam Line 5 R M 1, 2, 3, 4
- 2. Process Monitors -
- a. Fuel Storage Pool Airborne -
- i. Gaseous # # # ..*
ii. Particulate / Iodine # # # * -
- b. Containment Airborne
- i. Gaseous @ @ @ All [
ii. Particulate @ @ @ All m iii. Iodine @ @ @ All h$
- e. 3
~'l
- c. Control Room Airborne ,
Particulate "
- i. # # # All I -
2 Gaseous fi. # # # All 2- \ t, e
= .. i O ,
j j
- = . . . .
5 AD
~
\ i 1 y TABLE 4.3-3 j RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS 2 7 CHANNEL MODES FOR WHICH c;i CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE
$ INSTRUMENT CHECK CALIBRATION TEST IS REQUIRED PROCESS MONITORS (Continued)
- 3. Noble Gas Monitors
^
N Plant Vent Stack -
@ @ @ All
**b. Condenser Evacuation System 0 0 @ All M * .
NOTES: { e
# l In accordance with Table 4.3-2 surveillance requirements for these instrument channels. i With irradiated fuel in the storage 001. "Jd To be operational prior to initial -e-iticdity.*j; 8[" '*^ '" N
- U.
E In accordance with Table 4.3- surveillanceWs70r these ins rument channels. f '"? klk We A*v tT McehN (t)G4 JLY prnte sh sy { g tof M inktd M r lh o MODE I . U
-k
- I
- i TTI f-to ;
O . _ _ . . . f 5
~~
?
TABLE 3.3-10
=
@ ACCIDENT MONITORING INSTRUMENTATION (CONTINUED) .
?
A E- REQUIRED MINIMUM 5* NUMBER OF CHANNELS CHANNELS OPERABLE o -INSTRUMENT
- 19. Containment Area Radiation - High Range 2 1 .
**20. Main Steam Line Area Radiation 1/ steam line N.A. .
**21. Condenser Evacuation System Radiation Monitor - 1 N.A.
Wide Range
**22. Purge / Vent Stack Radiation Monitor - Wide Range
- 2 1
- 23. Cold Leg HPSI Flow 2/ cold leg 1/ cold leg .
R 24. Hot Leg HPSI Flow 1/ hot leg N.A. u
'Y NOTES:
i @; ,3
*The two required channels are the Unit 2 monitor and the Unit 3 onitor. ', ' ' ' '
**To be operational prior to initial ;-iticalit, o rar'Ah.n a b.ve @ N - :
9 -
; l i
0 ' '-
? - .
5 . .- t h I ( ?
TABLE 4.3-7 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS (CONTINUED) { CHANNEL CHANNEL i INSTRUMENT CHECK CALIBRATION
- 19. Containment Area Radiation - High Range (a) (a)
**20. Main Steam Line Area Radiation (a) (a)
**21. Condenser Evacuation System Radiation Monitor - M R Wide Range
**22. Purge / Vent Stack Radiation Monitor - Wide Range H R
- 23. Cold Leg HPSI Flow M R
- 24. Hot leg HPSI Flow M R .
3 l
?> 1 NOTES: E7 ,
In accordance with Table 4.3-3. y (a) 'I
= To be operauonal prior to inidal "ppdie N ;WE 2
i i rl .:- . to V . g i.- j __ l- . ,
- ! ___ . i m ?>
, . C3 . . ..
- TABLE 4.3-8 (Continued) %] h [.[J[ hk
, TABLE NOTATION (1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and entrol room alars annunciation occurs if any of the following conditions exists:"
- 1. Instrument indicates measured levels above the alarm / trip setpoint.
- 2. Circuit failure. . . -
- 3. Instrument indicates a downscale failure.
(2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that narticipate in measurement assurance activities with NBS. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used. CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once per 24 hours on days on which continuous, periodic, or batch releases are made. w D y y y;.ka). NMkL cAustATtd skil k shgA Y"f
)
%y ; ucock Ak FsM. Ad. u 5 23 6 2 "*N Libit geath aben G % aus- '
l s u,hud CHANklEL FouCTlou^L TEST skaII I"'AI'~ t w t4 w 4 g % f Gck.l+.2.Iz.u &gp&acur w %bF.fALso Aug Y in .
,. m .
"If the instrument controls are not in the operate acde, procedures shall call for declaring the channel inoperable.
i { ( l SAN ONOFRE-UNIT 2 3/43-67 FEB o 1582
. TABLE 3.3-13 - ,
RADI0 ACTIVE CASE 005 EFFLUENT MONITORING INSTRUMENTATION . . 2 MINIMUM CHANNELS k OPERABLE APPLICABILITY ACTION
; INSTRUMENT i 1. WASTE GAS HOLDUP SYSTEM I a. Noble Gas Activity Monitor - g 3 6 -78 M
- Providing Alarm and Automatic j 35 Termination of Release - 2/3 RT - 814g
- b. Effluent System Flow Rate Measuring
- Device 1 36
- 2. WASTE GAS HOLDUP SYSTEM EXPLOSIVE GAS MONITORING SYSTEM '
** 39
- a. Hydrogen Monitor 2
- b. Oxygen Monitor 2 39 -
3. CONDENSER EVACUATION SYSTEM 2 Noble Gas Activity Monitor - 2RT - 7818 or
# r - = a.
2RT - 7870 '=^^ ~ 1 *#N 37, (a) ' t a b. Iodine Sample 1
*f 4 40 40
- c. Particulate Samp 1 1 **IMA4
- d. Flow Rate Monito- 1 36 .
- 4. PLANT VENT STACK -_
N a.fNoble Gas Activity Monitor - bevil!- 1
- 37,(a) $
f . . - . _ - _ ______i Terminati r ef
- r.3 Ecicose irum Wa>Le Gas Siusayc Ianka -
- 2/3 RT - 7808,er- 1f t-78M-1 W 3 CI-786f-l Ro g
- 40 .~. 1
- b. i am e -
- 40
- c. Particulate Samp C.J
! d. Flow Rate Monito 1 1
* $ 36 ;. j -
l
- e. Sampler Flow Rate Measuring Device. 1
- 36 i;f * {
Tu
- 5. CONTAINMENT PURGE SYSTEM cm
'1
@ a. Noble Gas Activity Monitor - Providing ' 'd o Alarm and Auto ic Termina 'o of Release *
- 2RT - 7804-1 = 2PT - 79 7-? L' 1 38,(b),(c)
- 40, (c) g b. Iodine Sampler __ 1 Particulate Samp 40, (b), (c)
<g c. 1
- d. Flow Rate Monito # 1
- M- 36
- e. Sampler. Flow Rate Mci;,uring Device 1 36 .
l
l -- --
.. ,, , ,u,.a,,..... .'f(i"'~.' ,
1/. lit t f401 AllON At all times. During waste gas holdup system operation (treatment for primary system offgases).
*** To be operational prior to exceeding 5% RATED THERMAL POWER.
a) In accordance with Table 3.3-6 ACTION 19 b) In accordance with the ACTION Requirements of Specification 3.4.5.1 (Modes 1, 2, 3 and 4) c) In accordance with the ACTION Require nt f Specification 3.9.8 Mode ' W To bre o nabbw( ior '$ Orl' lA{ CMhtCAffY AI f 3 i e m er o a ne ess than required by the Minimum Channels OPERABLE requirement, the contents of the tank (s) may be released to the environment for up to 14 days provided that prior to initiating the release:
- a. At least two independent samples of the tank's contents are analyzed, ard
- b. At least two technically qualified members of the facility Staff independently verify the release rate calculations and discharge valve lineup; Otherwise, suspend release of radioactive effluents via this pathway.
ACTION 36 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided the flow rate is qstimated at least once per 4 hours. ACTION 37 - With the number of channels OPERABLE less than rey' aired by the l Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once per 8 hours and these samples are analyzed for gross activity within 24 hours. ACTION 38 - With the number of channels OPERABLE less than required by the , Minimum Chnnels OPERABLE requirement, immediately suspend l PURGING of radioactive effluents via this pathway. l ACTION 39 - With the number of channnels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, operation of this system may continue for up to 14 days. With two channels inoperable, be in at least HOT STANDBY within 6 hours. l ACTION 40 - With the number of channels OPERABLE less than required by the l Minimum Channels OPERABLE requirement, effluent releases via j the affected pathway may continue for up to 30 days provided i samples are continuously collected with auxiliary sampling ( equipment as required in Table 4.11-2. _ l FEB 011952 l cau nuncor-nun , m ,_ ,n _
ou Gl q,g{\ TABLE 4.3-9
+ ,
f ,f' RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS
! \:
I/ CHANNEL MODES FOR WHICH SURVEILLANCE I . CHANNEL SOURCE CHANNEL FUNCTIONAL
- INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED I 1. WASTE GAS HOLDUP SYSTEM
- a. Noble Gas Activity Monitor - .
Providing Alarm and Automatic
- 1) Termination of e -
,%f 2/3 RT - 7814 # f/3 CT-78#8 P P R(3)(1/ Q(1)(B)
'f b. Flow Rate Monitor , P N.A. R (1) Q (8) *
' 2. WASTE GAS HOLDUP SYSTEM EXPLOSIVE .-
GAS MONITORING SYSTEM
- a. Hydrogen Monitor (continuous) D N.A. Q(4) M
- b. Hydrogen Monitor (periodic) D N.A. Q(4) M w
- c. Oxygen Monitor (continuous) D N.A. Q(5) M 3 d. Oxygen' Monitor (periodic) D N. A. Q(5) M
- 3. CONDENSER C ATION ST TEM
- a. Noble as tiv# #ity Mo 1 -
2R. - 1 , 2RT - - D M R(3) Q(2) *Ad
- b. Iodint ' ^ -
W N.A. N.A. N.A.
*II ts
- c. Particulate Sample W. N.A. N.A. N.A. *AI 73 O
- Y *g#
- d. Flow Rate Monito " - D N.A. R Q E,. 3
- 4. PLANT VENT STACK g,
- a. Noble Gas Act i tv Mn gT-10
- 2/3 RT - 780f edCT-7845-I '" M R(3)(1) Q(2(8) g
. b. Iodine Sample W N.A. N.A.
~
N.A.
- 7 i
- I
- c. Particulate Sample W N.A. N.A. j N.A.
!, d. Flow Rate Monito D N.A. R
(~T) *N Q (8) '
- e. Sampler Flow Rate Measuring .
(
- i
.- Device D N.A. R
{~I) L Q(B
; Vl
TABLE 4.3-9 (Continued) C E RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS S 4 4 6 CHANNEL MODES FOR WHICH L CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED o 5. CONTAINMENT PURGE SYSTEM .
- a. Noble Gas Activity Monitor - '
Providing Alarm and Automatic tion of Rele e-
-W-hRT - 7804- __ - 7S07 2 S P(6) R(3)(7) M(1)
- b. Sampler W N.A. N.^. N.A.
- c. Particulate Sample q W N.A. N.A. N.A. v -
, d. Finw Rate Monito , D N.A. R
(.1) Q *U - S e. Sampler Flow Rate Measuring j i y Device D N.A.
- R Q _
e I
- e
! M i - Ei ,l c .3
' n'; I CI'* {
I l-m - rn W b ,,o - l"l , s~ c ,!a N U:.' ' l' L! l l l I
.I'2.U..i: 2 - .\.-
T At:t r 101 A110fJ u -~" A 1,e c, . uk Neleewe vnoeshe m * ,,,% 9, 7.Q.T tt.o7 'Z- M be_
" uri E 1y> no ys e pr e 75o4 -\
p . . _ _ry system offgases).
~@ tty"MT"T"aWi c~u,%s. ' hat""-
(1 T C FUN nstrat automatic isol ion of t is pathway and control r any of the following conditions exists:gom alarm annunciation occurs if
- 1. Instrument indicates measured levels above the alarm / trip setpoint.
- 2. Circuit failure.
- 3. Instrument indicates a downstale failure.
(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control roop alarm annunciation occurs if any of the following conditions exists :
- 1. Instrument indicates measured levels above the alarm setpoint.
- 2. Circuit failure,
- 3. Instrument indicates a downscale failure.
(3) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used. (4) The CHANNEL CALIBRATION shall include the use of standard gas samples l containing o. nominal:
- 1. One volume percent hydrogen, balance nitrogen, and l 2. Four volume percent hydrogen, balance nitrogen.
(5) The CHANNEL CALIBRATION shall include the use of standard gas samples containing a nominal:
- 1. One volume percent oxygen, balance nitrogen, and i
t ?.. Four volume percent oxygen, balance nitrogen. l ~ l iTor to eachh n e st,once p'er Sont M.['7'4f'2U l (,1) ihf ftf a#n>}2k #jor tb' iriefi4 l . erANow r ikk Sk abNt. & f?YOfM 5)( oatf f ' 1 con rols re n et - me e >
, edures shall call cjAt g the channe inoperable. f ,
/ ,
ri.. .o ~i.,uu sJ m. . 3/4a3-73m~< / - SAN ONOFRE-UNIT 2
! r r, -
n.c.. . ; IAE!t 4.11-1 "- ' - - o RAD 10ACTIVI L10lllD WA51f SAMPLING AND ANALYSIS PROGRAM
=O Lower Limit Minimum of Detection Liquid Release Sampling Analysis Type of Activity (LLD)
Type frequency Frequency Analysis (pCi/ml)a A. Batch Waste P P Release Each Batch -7 ' d Each Batch Principa} Gamma 5x10 Tanks Emitters 1.' Primary Plant -6 . I-131 1x10 Makeup Storage lx10 -5 Tanks P M Dissolved and
- 2. Radwaste Primary One Batch /M Eritrained Gases Tanks ,
(Gamma emitters)
.Rgg&803ryTanks Each Batch Compos te b
H-3 lx10 -5
- 4. Miscellaneous _7 Waste Condensate Gross Alpha 1x10 Monitor Tanks
- 5. Neutralization P Sr-89, Sr-90 5x10
-8 Sump Q b Each Batch Composite
-6 Fe-55 lx10
* ~7 D W Principa} Gamma 5x10 B. Continuous' Releases Grab Sample Composite c
Emitters
- 1. Steam Generator I-131 lx10 -6 Blowdown
-5
- 2. Turbine Building M M Dissolved and lx10 Sump Grab Sample Entrained Gases
- 3. Miscellaneo s (Gamma Emitters)
Waste Eva ora r Condensat g c -5 Grab ample Compo ite H-3 lx10
-7
- 4. Salt Water Gross Alpha lx10 Discharge From Component Cooling Heat D Q Sr-89, Sr-90 5d0 -8 c
Exchanger Grab Sample Composite -6 Fe-55 lx10 FEBOI1982 CAN ONnrDF-IINTT 7 "4/4 11-7 - - - - w -
E _. TABLE 4.11-1 (Continued; 0
. t MO][ c. 1"a:"l
- m. CDPy "
. TABLE NOTATION
- b. A ccnposite sample is one in which the quantity of liquid sampled is pr:per:icnal to the cuantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.
- c. To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be
. collect d continuously in proportion to the rate of flow of the ..
effluent stream. Prior to analyses, all samples taken for the composite shall be throughly mixed in order for the composite sample o be representative of the effluent release. A batch release is the disefiarge of liquid wastes of a discrete _ d. volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed, by a method described in the ODCM, to assure representative sempling. .
- e. A continuous release is the discharge of liquid wastes of a nondiscrete volume; e.g., from a volume of system that has an input flow during the continuous release.
- f. The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, 1 together with the above nuclides, shall also be identified and j reported. -
l y rampY%q li nis hk hd is nd ra.yre.L]k. caMCt
- L utct.
w v46. is verik'el LchA sbt. 4 kC y derg 31 s - Q g deste y bvt I hok h4- qM icAh5 Mb/
/ g h qws. L & brk AWMTf2ATd I
cuNyllot3 s d\ foVY Y JAmp ih3 wh U-( . . .
- FEB 011982 l =
d , TABLE 4.11-2 . w RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM
.?
o 8 Minimum Lower Limit of 2 Sampling Analysis Type of Detection (gt0)
- Gaseous Release Type Frequency Frequency Activity Analysis (pCi/ml)
P P F A. Waste Gas Storage Each Tank Each Tank Principal Gamma Emitters 9 1x10 4
.".? Tank Grab o M Sample '
B. Containment Pu'rge h P P Principal Gamma Emitters 1x10 4 ch Purgeb ,c b - 42 inch Each Purge b 6 inch *MD M Principal Gamma Emmitters 3x10 4 ,. Grab Sample H-3 1x10 6 . D b ' C. 1. Condenser M M Principal Gamma Emitters 9 1x10 4 Evacua ' n Grab y . Syste fHfd Sample H-3 1x10 8
- 2. Plant Ven d
T' Stack N D. All Re1 Types Continuous # I-131 1x10 12 as li ed'in and Sampler Charc 1 C abov . h Samp e # I-133 1x10 10 d Continuous I W [ Principal Gamma Emitters 9 1x10 11 Sampler Particu%. t( (1-131, Others) tp Sample Contiriuous# Sampler M Composite Gross Alpha 1x10 11 M p~ ., Particulate us g Sample .
!s ]*l a Continuous, Q Sr-89, Sr-90 1x10 11 l; I Composite '
- Sampler
- s Particulate .
R! . Sample f: ,ll s Continuous # Noble Gas Noble Gases 1x10.s s
- -l Mo nitor Gross B, eta or Gamma -. !
~ - ~-~
- + - . :. r 0. .A .~ h . tJ'. ,, n .~ A . VM a41-wTn%1 crikli-k i
, n -
' TABLE 4.ll-2 (Continued) g{ n.
TABLE NOTATION
- b. Analyses shall also be performed following shutdown, startup, or a THERMAL POWER change exceeding 15 percent of the RATED THERMAL POWER within a one hour period.
- c. Tritium grab samples shall be taken at least once per 24 hours when the refueling canal is flooded.
- d. Samples -shall be changed at least once per 7 days and analyses shall . . . .
be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least 7 days following each shutdown, startup or THERMAL POWER change exceeding 15 percent of RATED THERMAL POWER in one hour and analysts shall-te completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLD's may be increased by a factor of 10.
- e. Tritium grab samples shall be taken at least once pe'r 7 days from the ventilation exhaust from the spent fuel pool area, whenever spent fuel is in the spent fuel pool.
- f. The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.11.2.1, 3.11.2.2 and 3.11.2.3.
- g. The principal gamma emitters for which the LLD specification appiies exclusively are the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-235, and Xe-138 for gaseous emissions and Mn-54, Fe-59, y Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions. This list does not mean that only these t- nuclides are to be detected and reported. Other peaks which are measureable and identifiable, together with the above nuclides, l -te d .
(h.%w emu h a k askA ryoehh myl- mwen9 -y . - l ( FEB o f 1982 SAN ON0FRE-UNIT 2 3/4 11-11 _
.... c .-
. \
THIS PM : mq c
-INFORM 5Ilb5gh,]Q'jll[' T
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ri p ,....,my RADIOLOGICAL ENVIRONMENTAL MONITORING' ..w el d +4= A ' 3/4.12.2 LAND USE CENSUS LIMITING CONDITION FOR OPERATION 3.12.2 A land use census shall be conducted and shall identify the location I of the nearest milk animal, the nearest residence and the nearest garden" of greater than 500 square feet producing fresh leafy vegetables in each of the 16 meteorological sectors within a distance of five siles. (For elevated releases as defined in Regulatory Guide 1.111, Revision 1, July 1977, the land use census shall also identify the locations of all milk animals and all gardens of greater.than 500 square feet producing fresh leafy vegetables in each of the 16 meteorological sectors within a distance of three miles.) APPLICABILITY: At all times. ## . ACTION:
- a. With a land use census identifying a location (s) which yields,a calculated dose or dose commitment greater than the values currently being calculated in Specification 4.11.2.3, in lieu of any other report required by Specification 6.9.1., prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report which identifies the ,new location (s).
. b. With a land use census identifying a location (s) which yields a calculated dose or dose commitment (via the same exposure pathway) 20 percent greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, in lieu of any other report required by Specification 6.9.1, prepare and submit to the Coseission within 30 days, pursuant to Specifica-tion 6.9.2, a Special Report which identifies the new location. The new location shall be added to the radiological environmental monitoring program within 30 days. The sampling location, excluding the control station location, having the lowest calculated dose or dose commitment (via the same exposure pathway) may be deleted from this monitoring program after (October 31) of the year in which this land use census was conducted.
- c. The provisicc.s of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.12.2 The land use census shall be conducted at least once per 12 months between the dates of (June 1 and October 1) using that information which will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities. A Broad leaf vegetation sampling may be performed at the site boundary in the i directio u s or with the hi best D/ in lieu f CL44ys. 1ckevef s's tarhaf. Y 0f mn LA o Vb'50k bott $fo *Utf O Y hY j SAN ONOF 0]
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1 ..'. - . . - . . RADIOLOGICAL ENVIRONMENTAL MON!TORING 3/4.12.3 INTERLABORATORY COMDARISON PROGRAM LIMITING CONDITION FOR OPERATION 3.12.3 Analyses shall be perfomed on radioactive materials supplied as part of an Interlaboratory Comparison Program wnich has been approved by the Cossission. APPLICABILITY: At,alltimes.k ACTION: ,
- s. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report,
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.12.3 A summary of the ress. sits obtained as part of the above mquired Interlaboratory Comparison Program and in accordance with the CDCM 4er-
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, Environmental Operating Report.
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< g. PROCESS CONTROL PROGRAM .n:plementation.
- h. OFFSITE DOSE CALCULATION MANUAL implementation.
- 1. Quality Assurance Program for effluent and environmental monitoring, +,
using the guidance in Regulatory Guide 4.15 Rev. 1, February 1979.
- j. Modificaticn of Core Protection Calculator (CPC) Addressable Constants.
NOTE: Modification to the CPC addressable constants based on in .mation obtained ~ through the Plant Computer - CPC data link shall not be made witholJt prior approval of the Onsite Review Committee. - 6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed and approved by the Station Manager; or by (1) the Station Operations Manager, (2) the Station Technical Manager, (3) the Station Maintenance Manager, (4) the Station Deputy Manager or (5) the. Health Physics Manager as previously " designated by the-StatioManagen prior to implementation and shall bt refiewed periodically as set forth in administrative procedures. 6.8.3 Tamporary changes to procedures of 6.8.1 above be made provided:
- a. The intent of the original procedure is not altered.
L b. The change is approved by two members of the plant managem'e*nt staff,
- at least one of whom holds a Senior Reactor Operator's License on the unit affected.
- c. The change is documented, reviewed and approved by the Station Manager; or by (1) the Station Operations Manager, (2) the Station l
Technical Manager, (3) the Station Maintenance Manager, (4) the l Deputy Station Manager or (5) the Health Physics Manager as previously designated by the Station Manager; within 14 days of implementation. l 6.8.4 The following programs shall be established, implemented', and maintained:
- a. Primary Coolant Sources Outside. Containment l A program to re' duce leakate from those portions of systems outside containment that could cuntain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the high pressure safety injection recirculation, the shutdown cooling system, the reactor coolant sampling system (post-accident sampling piping only), the containment spray system, the radioactive waste gas system (post-accident sampling return piping only) and the liquid radwaste system (post-accident sampling return piping only). The program shall include the following:
(i) Preventive maintenance and periodic vistral inspection 9 requirements, and (ii) Integrated leak test requirements for 01ch system at refueling cycle intervals or less. .- , FEB'01 1982
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SUMMARY
OF SCHEDULE REASON SCHEDULE RELIEF JUSTIFICATION FOR
- MONITOR STATUS RELIEF REQUESTED IS REQUIRED SCHEDULE RELIEF
- 1. a) Control Room Airborne Presently.at least Accept calibrations performed Schedule relief is required The combination of vendor -
monitor RF-7874/7825 one channel of each during the.startup program in in order to provide sufficient and field calibrations b) Containment Airborne monitor has been conpliance with FSAR section time for enhanced calibration (per FSAR 11.5.2.1.5.2) monitor RE-7804/7807 calibrated (Per 11.5.2.1.5.2 in place of the of these monitors to be per- are the design basis of c) Containment Purge Area FSAR 11.5.2.1.5.2) CHANNEL CAllBRATION requirements formed in a timely manner the plant. These cali-1 Mnnitor RE-7856/7857 and has completed of the applicable tech. spec, consistant with the plant brations provide adequate d) Plant Vent Stack preoperational section prior to initial power evolutions during initial confidence that the Airborne Monitor testing per FSAR increase above 5% Rated Thernal startup, monitors are properly RE-7808 chapter 14 (Note P owe r. calibrated given the low
. Technical Specifica- probability for release
- i tions tables 3.3-6 and prior to exceeding 5% of l e) Hi-Range in 3.3-12 require only As above. Note: -Operability Rated Thermal Power.
Cont ainment one channel of each is not required until Mode 4 Periodic surveillances ' i Monitor RE-7820-1/ of these monitors per tech. spec. table 3.3-6. (CHANhEL FutCTIOhAL 7620-2 (a-d) to be operable) TESTS. CHAhhEL CHECKS. AND SOURCE CHECKS) per-formed in accordance with i approved Station pro-
! cedures provide add-itional confidence that these monitors will per-form as required in the unlikely event of an
- unplanned release. ,,
a 11. a) Radwaste Dis Presently each 1. Accept calibrations per- Schedule relief is required The combination of vendor j charge Line monitnr has been forned during the startup to allow available resources and field calibrations Monitor Rr-7813 chalibrated (per FSAR. program in compliance with to be concentrated on per- (per FSAR 11.5.2.1.5.2) i b) Blnwdown Neutra- 11.5.2.1.5.2) and FSAR section 11.5.2.1.5.2 torming the upgrade program and preoperational test lization Sump has been preopera- and functional testing on the highest priority results (per FSAR 14.2. f:onitor RE-7817 tinally tested per performed in accordance with monitors, thereby completing 12.22) provides adequate c) Turbine Building FSAR chapter 14 FSAR section 14.2.12.22 in the enhanced calibrations confidence that the mon-Sump Monitor place of the CHANNEL Call- at the earliest cate achiev- itors are properly cali-RE-7821 BRATION and CHANNEL FUNC. able brated and operable. i TIONAL test requirements Prior to Initial of the applicable tables Criticality no fission I- until power increase above product inventory exists j 51 Rated Therral Power in the plant and there-
- 2. Defer repetition of sub- fore no possibility of sequent CHANNEL FUNCTIONAL release through these TEST until 30 days after paths exists. Between i initial criticality. Initial Criticality and 51 Rated Thermal
! Pcwer the accumulated radwaste volume is i very small and the prob-ability for an uplanned l t release is extrenely low. ' i
- l. d) Steam Jet Air Not Presently operable Not required until Initial Prior to Initial
! Ejector Monitor Criticality Criticality 4 RE-7818 AKB no possibility of release i via the SJAE exists i!
- ENCLOSURE 3 Justification for Schedule Relief on Installation of Proportional Samplers The following liquid continuous release paths will have proportional samplers installed by January 1,1983. Operation without proportional samplers is acceptable during the interim period for the reasons provided.
- 1) Steam Generator Blowdown - FSAR figures 10.1-1, sheet 1 and 10.4-2, sheet 1 provide the Pt.ID's for the steam and power conversion system as well as the blowdown processing system. Normally , fluid processed by the steam generator blowdown system is returned to the condensor hotwell. In the event of high conductivity alarm in this line, the fluid is diverted to the outfall header via the pathway monitored by the neutralization sump discharge monitor (RE7817).
Upon receipt of a conductivity alarm, the blowdown system effluent will be sampled as necessary to obtain an equivalent proportional sample such that the requirements in Technical Specification Table 4.11-1 are met.
- 2) Turbine Building Sump - FSAR figures 9.3-2, sheet 2, 9.3-3 and 9.3-4, sheet 1 provide the PalD's for the turbine building and related sumps. The turbine building sump collects drainage from the auxiliary building sump, intake area and all normal equipment and floor drainage from the turbine plant area. The turbine plant area sump normally discharges to the oily waste sump; however, upon a high radiation signal on monitor RE7821, the discharge is automatically diverted to the radwaste area sump. The probability of radioactivity in the turbine plant area sump is low. The discharge from the oily waste sump will be manually sampled prior to and during a discharge to the outfall.
- 3) Miscellaneous Wastes Evaporator Condensate - FSAR figures 11.2-1, sheet 2 and 11.2-3, sheet 2 provide the P&ID's for this potential release path. The discharge from the miscellaneous waste evaporator is normally directed to the evaporator condensate monitor tanks.
These tanks are provided with an installed by-pass line which could permit the evaporator condensate to be discharged without being sampled as a batch release. The by-pass line valve 1415-2 1/2"-200 is normally locked closed. Monthly surveillance will ensure that this valve remains locked closed. 3 l,[ ,q
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a) Salt Water Discharge from Conponent Cooling Heat Exchanger - FSAR section 9.2.1 and 9.2.2 describe the saltwater cooling and component cooling water systems. The conponent cooling water system of each unit is designed to remove heat from the various auxiliary systems containing radioactive or potentially radioactive fluids. It
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provides a radioactivity monitored (by radiation monitor RT7819 and grab sampling) intermediate barrier between the reactor auxiliary systems fluids and the saltwater cooling system. Separate and distinct mechanical boundaries prevent radioactive water f rom entering the saltwater cooling system. The first boundary would be a heat exchanger (e.g., shutdown heat exchanger). The second boundary is the component cooling heat exchanger tube wal l s. Both of these boundaries must be breached to allow radioactivity to enter the saltwater cooling system. The component cooling water system is periodically sampled for activity. These grap samples would indicate any activity in the component coolding water system in the unlikely event that a passive pressure boundary failed. The component cooling water system has surge tank volume of approximtely 5,000 gallons. Significant leakage of potentially radioactive fluid into or out of the component cooling water system would result in a surge tank high/ low level alarm. The difference in volume between the normal level and high/ low level alarm is approximately 900 gallons. Significant leakage would therefore be rapidly detected by the operators and appropriate measures taken. As the salt water cooling system flow is fixed, routine manual sampling of this system will result in a sample which is proportional to the volume discharged. This is acceptable until such time as continuous proportional samplers can be installed. i+- n mi %_t 281.9 89- m . .e - . h h
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- ENCLOSURE 4 DISCUSSION OF CONTAINMENT PURGE SA W LING PRESENT PROVISION, Two NMC gaseous radiation monitors, RE-7804-1 and RE7807-2, (FSAR-11.5.2.1.4.5) presently monitor containment airborne activity. Monitor RE-7804-1 samples the containment atmosphere at approximately elevation 90 feet (sane vicinity as the mini-purge exhaust) and moniter RE-7807-2 .
samples at approximately elevation 35 feet. Extensive mixing of the containment atmosphere by the normal HVAC units ensures that either sample location is representative of the entire containment atmosphere, and therefore considered to he representative of the containment purge effluent stream. In particular, either sample location will be representative of the large purge-system effluent stream, due to the multiple distribution lines of this system within containment. These monitors provide the capability for Iodine, . particulate and gas grab sampling. A correction factor will be applied to the sample analysis to account for sample line deposition. Flow indication is provided on the monitor. Based on the above, these monitors will be used to obtain composite samples of the purge stream as required by Technical Specifications.
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