ML20083F905
| ML20083F905 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/06/1984 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20083F897 | List: |
| References | |
| NUDOCS 8401100410 | |
| Download: ML20083F905 (29) | |
Text
\\
INSTRUMENTATION METEOROLOGICAL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.4 The meteorological monitoring instrumentation channels shown in Table
.3,3-8 shall be OPERABLE.
APPLICABILITY: At all times.
ACTICN i
Wlht k num t'r of dtaand5 y
{m % k oinimum ;nbb/ :n We334 a.
With cr.c cr nr... quired metT5rciogical musiii,0MchTnnels inoperatrie-for more than 7 days, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the malfunction and the plans for restoring the channel (s) to OPERABLE status, b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.4 Each of the above meteorological monitoring instrumentation channels shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-5.
J ".
'l e
vie 80sa8sy, PDR WOLF CREEK - UNIT 1 3/4 3-47 I
. _ - - ~.
SPEClFiCAT.'oN 3.334-JUSTIFICATION:
quAk5 Theflexibilityofoperationj.bybackupmeteorologicalinstrumentation is negated by requiring Special Reports for single channel inoperability.
The proposed revision allows this flexibility while providing assurance that instrument malfunctions will be corrected in a timely manner.
~
)edZ -6d'didS" TABLE 3.3-8 l
. \\
k xMETEOR0 LOGICAL MONITORING INST'RUMENTATJO INSTRUMENT LOCATION 0
BE 1.
Wind Speed Nomi 1 Elev. 10m 1
omi al Elev. 60m 1
2.
Wind Direction Nominal E
- v. 10m 1
Nominal Elev.
Om 1
Air Temp /
3.
erature - AT Nominal Elev. 10m-60 1
c e
O k.
P 4
WOLF CREEK - UNIT 1 3/4 3-48' w -
,y
--c-,
,-w.
. -,_-w w
.Tnserf TABLE'3.3-8.
METEOROLOGICAL MONITORING INSTRUMENTATION MINIMUM INSTRUMENT LOCATION OPERABLE 1.
Wind Speed 10m, 35m, 60m 1
2.
Wind Direction-10m, 35m, 60m 1
3..
A-Temperature 10-35m,10-60m, 10-85m 1
WOLF CREEK - UNIT 1 3/4 3-48
3 t
TABLE 3. s -8 JUSTiFic4TIOW The reason for several different elevations for measuring devices is to provide backups for the primary (10m) instruments. So long as one channel is available, there is no loss of information.
D
3 -
4'
N
)e/eb:Sec TABLE 4.3-E
/d5N METE 0$LGOICALMONITORINGINSTRUMENTATION SURVEILLANCE REQUIREMENTS s
N_'
CHANNEL CHANNEL INSTRUMENT CHECK CALIBRATION 1.,
Wind Speed a.
Nominal Elev;.10m D
SA b.
Nominal Elev. 60s O
SA WindDirectioi[
2.
a.
Nominal EYev. 10n D
SA s
-m b.
Nominal Elev. 60m D
SA 3.
Air Temperatare - AT 1,
a.
Nominal Elev.'10-60m D
~
g 5
s f.
s M
e 4
S i
/2 P
4 c
WOLF CREEK - UNIT 1 3/4 3-49 c
?
Insert TABLE 4.3-5 METEOROLOGICAL MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL I_NSTRUMENT CHECK CALIBRATION 1.
Wind Speed D
SA l
l 2.
Wind Direction D
SA 3.
A-Temperature D
TABuG 4:35 JUSTenchTs0H:
The reason for several different elevations for measuring devices is to provide backups for the primary (10m) instruments. So long as one channel is available, there is no loss of information.
h 4
L
le 6
TABLE 3.3-6 I
G RADIATION MONITORING INSTRUMENTATION FOR PLF," OPERATIONS n
A Q
MINIMlM CHANNELS CHANNELS APPLICABLE ALARM / TRIP FUNCTIONAL UNIT TO TRIP / ALARM OPERABLE MODES SETPOINT ACTION c-5 H
1.
Containment e
a.
Containment Atmosphere i
Radioactivity-High 1 M+
26 l,
(GT - rr - s i, n
,a e, 4 i, z,3,4 j
l b.
COntain;;Gt Purs; Ed.au;t R :'icact! Jity-a fligh 1
2 All 20 c.
Gaseous Radioactivity-RCS Leakage Detection N.A.
I 1,2,3,4 N.A.
29 wg
( Gr-ge - 3,3 z.)
d.
Particulate N.A.
I 1,2,3,4 N.A.
29 w
i Radioactivity RCS Leakage Detection o
(cer_ ce - si, 3 z) 2.
Fuel Building Spent phere.
Atrnes.ue! Pee!
a.
$ fyf,~5 c/,ec 27 Radioactivity-High 1
4 (es - cc. - zi,2 s) i b.PX* Criticality-Ebb i'
(CD - r<G-5 7,52) 1
-< 15 mR/h 28 Radiation Level 1
e i
3.
Control Room f
Air Intake Radioactivity-High 5./yi.-$(g, (6K-M-04.06) 1
+
All 27
4 i
l TABLE 3.3-6 (Continued)
TABLE NOTATIONS
- With fuel in the fuel storage areas or fuel building.
- With irradiated fuel in the fuel storage areas or fuel building.
- Must satisfy Soecification 3.11.2.1 requirements,and is appl.cabk kiy fd")*
gv.ati on o.g.
i ACTMN STATEMENTS, ACTION 26 - With'less than the Minimum Channals CPERABLE requirement, operation may continue provided the contf*.inment purge valves are maintained closed.
ACTION 27 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the Control Room Emergency Ventilation System and initiate operation of the Control Room Emergency Ventilation System in the recirculation mode.
ACTION 28 - With less than the Minimum Channels OPERABLE requirement, operation may continue for up to 30 days provided an appropriate portable continuous monitor with the same Alarm Setpoint is provided in the fuel area. Restore the inoperable monitors to OPERABLE status within 30 days or suspend all operations involving fuel movement s.
in the Fuel Builidng.
1 ACTION 29 - Must satisfy the ACTION requirement for Specification 3.4.6.1.
t
^
N>*
- ~11? C 3/4 3-42 e
e
-.r.
..,_..,o..
........,w_.
...E Z..
Table 3.3-6 Justifications:
2(a) and 3(a): At this alarm point emergency ventilation is actuated.
Footnote #:
These monitors provide a trip function which terminates purges before the limits of 3.11.2.1 are exceeded.
l l
l
1 1
1 1
1 TABLE 3.3-13 1
s-p RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION l
n n
MINIMUM CHANNELS h
INSTRUMENT OPERABLE APPLICABILITY ACTION n
1.
WASTE GAS HOLDUP SYSTEM Explosive Gas 3
Monitoring System l
% 44-G a.
Hydrogen Monitor 1/recombiner l
g 42 l
b.
Oxygen Monitor 2/recombiner l
2.
Unit Vent System (cer CE il) 1 40 a.
Noble Gas Activity Monitor --F.u.;dii,9 1
M ere-tRE-21-)
Iodine?.cthIl["cr. iter ("E-21) 43 1
R b.
a Particulate Ac N t[ "e;,ite-- (RE 21) 43 1
9
<t>
c.
-^--
33 d.
Elsw ";t; "sr.itor 1
39 e.
Sampler Flow Rate Monitor 1
3.
Containment Purge System (cr
- 6 -2 2, c,-r - a c - n, cx - gc - s i, co r - ac - sr.)
a Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release
" * + -
- 41 (ME-22, RC-33, RE-31, RE-32) 1 t
43
- b. La; c 5.
p < <
g
- c. RAndde s.. ple <
i 43
=A r_
e i.
Mr_ ". l ~
l v-u Set t
Rdc 14 e.d h <
(
e. %p < < Fiee
TABLE 3.3-13 (Continued)
RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION g
MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION 4.
Radwaste Building Vent System t enilce (6rH- #c - s e) t Eq a.
Noble Gas Activity Moaltor - Providing Alarm and Automatic Termination of Wasic C-o Iki'r Jyskw g
Release W 10) 1 38, 40 43 b.
Iodine Activity Monitor (RE-10) 1 43
- c.
Particulate Activity Monitor (RE-10) 1 i'
^
5^
d.
fle.; Cat Me.ite.
I 39 e.
Sampler Flow Rate Monitor 1
I 8
1 I
.. -. - ~... -....
TABLE 3.3-13 JUSTIFICATIONi The generic standard tech spec table does not reflect the SNUPPS Plant design. The table has been revised to refleet actual site specific design in regard to gaseous effluent monitoring instrumentation.
Explosive gas monitoring instrumentation is provided on the hydrogen recombiners for the Waste Gas Holdup System. Since SNUPPS design has two recombiners, which can be operated independently, a number /recombiner format is used to specify the mini =um channels operable requirement. By system design, only the inlet hydrogen monitor for each recombiner provides controlling functions. However, a process hydrogen monitor on the recombiner outlet will alarm and alert operators to conditions of potentially high hydrogen concentrations.
Provided one of the hydrogen monitors is functional, sufficient on-line monitoring is provided to measure and control hydrogen concentrations and ensure safe operation of the Waste Gas Holdup System.
Airborne effluent radioactivity monitors are identified and described in Section 11.5.2.3.3 of the SNUPPS FSAR. Table 3.3-13 has been revised to incorporate these monitors. In addition to the Unit Vent and Radwaste Building Vent instrumentation, the Containment Purge System monitor has been included in the table since these monitors have pathway isolation functions which will automatically terminate a containment purge.
Containment integrity is not required to be maintained during modes 5 & 6 with the exception of Core Alterations during mode 6.
The proposed change deletes surveillance and operability require-ments in modes where initiating signals from these monitors are not required to function or to be operable.
TABLE 3.3-13 (Continued)
TABLE NOTATIONS
- At all times.
- During WASTE GAS HOLDUP SYSTEM operation.
nWen hcas I' a.' 3* 4 ud duriD. cc.e
. ACTION STATEMENTS ACTION 38 - With the number of channels OPERABLE less 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, and b.
At lecst two technically qualified members of the facility staff independently verify the release rate calculations and diccharge valve lineup.
.T@
Otherwise,suspendreleaseofdadioactiveeffluentsviathis pathway.
ACTION 39 - 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 estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
l' ACTION 40 - With the number of channels OPERABLE less than required by the Minimum C5annels OPERABLE requirement, effluent releases via this pathway may continue.for up to 30 days provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
ACTION 41 - With the number of channels OPERABLE less than required by the Minimum Channels npERABLE requirement, immediately suspend PURGING of radioactive effluents via this pathway.
ACTION 42 -
he number of channels OPERABLE one less than required Minimum OPERABLE requirement, cperation
' system may continue provi samples are
- nd analyzed at least Sex. L u i every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With both c inoperable, operation may k-continue provided p es are take alyzed at least every 4 Jour ring degassing operation and at e 24 p*y h 3#ll Mduring other operations.
ACTION 43 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the affected pathway may continue for up to 30 days provided samples are continuously collected with auxiliary sample equipment as l
required in Table 4.11-2.
' ACTION 44 - With the number of channels OPERABLE one less than required by the I
Minimum Channels OPERABLE requirements, suspended oxygen supply to the recombiner.
WOLF CREEK - UNIT 1 3/4 3-71
_ _ _ - _ =
Insert Page 3/4 3-71 ACTION 42 l
With the Outlet Oxygen Monitor Channel inoperable, operation of the system may continue provided grab samples are taken and analyzed at least every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With both channels inoperable, suspend oxygen supply to the recombiner. Addition of waste gas to the system may continue provided grab samples are taken and analyzed every 4 hcurs during degassing operations for shutdowns and at least every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during other operations.
i
TABLE 3.3-13, TABLE NOTATION I
JUSTIFICATION _
l (1) ACTION 42.
Specification 3.11.2.5 provides for the continued safe operation of the WASTE GAS HOLDUP SYSTEM. The proposed sampling and analysis frequencies reflect the period when the maxinam amount of Gaseous Radwaste is being added to j
the system and are therefore designed to detect increases in the hydrogen / oxygen content.
e
TABLE 4.11-1 RADI0 ACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM 4
LOWER LIMIT MINIMUM OFDETECTg LIQUID RELEASE SAMPLING ANALYSIS TYPE OF ACTIVITY (LLD)
TYPE FREQUENCY-FREQUENCY ANALYSIS (pCi/ml)
Q. Batch Waste P
P
_7 Releag)
Each Batch Each Batch Princip 3 gamma 5x10 Emitters Tanks
-5 I-131 1x10
- a. Waste i
Monitor
-5 l
Tanks P
M Dissolved and 1x10 L
One Batch /M Entrained Gases (Gamma Emitters)
- b. Secondary Liquid
-5 Waste Moni-P M
H-3 1x10 tor Tank Each Batch Composite (4) g Gross Alpha 1x10
-8 P
Q Sr-89, Sr-90 g,1x10 Esch Batch Composite (4)
-6 Fe-55 1x10 h
Principk3 gamma 5x10 W
2.Continuog) Centinu: y Composite Releases Emitters D
N S"7
-6 I-131 1x10 q, Steam (b)
Generator
-5 Blowdown M
M Dissolved and 1x10 L.i e Grab Sample Entrained Gases (Gamma Emitters)
-5 El'U"3 g
)
H-3 1x10 ContdevettsN) Composit D' *;. y Disc 6
'D Gross Alpha 1x10"I L; *i t G..L k pc l
-8 Q
h Sr-89, Sr-90 5x10 Se,....uuu. g Composite
-6 b
Fe-55 1x10 G o.b % lc WOLF CREEK - UNIT 1 3/4 11-2
TABLE 4.11-1 (Continued)
TABLE NOTATIONS (Continued)
(3)The principal gamma emitters for which the LLD specification applies include the folicwing radionuclides: Mn-54, Fe-59, Co-58, Co-60, 4e-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144.
This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the semiannual Radioactive Effluent Release Report pursuant to Specification 6.9.1.7. 4n the format ewtlined in Regulet.eiy Guide 1.21, Appendix G, R.-;sico 1, Jun. 1974.
(4)A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen that is representative of the liquids released.
(5)A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g., from a volume of a system that has an input flow during the continuous release.
(S)Tc be repr::entative of the quantitic: and cone ntration: cf radic::tive material; in liquid effluents, comple: 0h:11 b; cellected ecntinucu:!y i-prcperticr tc the rate of fic.; cf th: Offluent :trcom.
I'rior tc analy:::,
all :::ple taken for th: : pc:it: : hell be thercughly mixed 4 7 crder for thn ccmpccit :;mple to be reprc: ntative of th: effluent rel :::.
(G) These sampl'n3 re.goirymeds buome cJ8ec6ve u> hen becc.n e_s d c< h.n +
sgstem in;h..tly\\l b secc.sacq h
c e dc.m. %+ <l.
Segico) rAuhady h dischu5[yfod g
e d
efflu.<n t M it be_
enq 6 m
- w. rc e m+-
WOLF CREEK - UNIT 1 3/4 11-4 W
>w w
F Table 4.11-1 TABLE NOTATION
- JUSTIFICATION:
(1)
Footnote 3:
Zn-65 was deleted since Zn-65 analyses are primarily applicable to BWR's with admiralty metal condenser tubes.
Per FSAR 4.5.1.1, the primary system does not contain any zinc.
based steel alloys; therefore there is no zine to be activated to Zn-65.
The reference to specification 6.9.1.12 was changed to 6.9.1.7 to correspond to the equivalent section of
'the proposed section 6.0 of the Wolf Creek Tech Specs.
(2)
Footnote 6: The steam generator blowdown monitor continuously monitors the blowdown line. Therefore, sampling prior to contamination of the secondary system is not required.
In addition, all releases from these systems are discharged through plant discharge monitors (LE-RE-52 or 59) if they are discharged to the environment.
f 4
RADI0 ACTIVE EFFLUENTS LIQUID RADWASTE TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION 3*.11.1.3 The Liquid Radwaste Treatment System shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see Figure 5.1-4) wculd eF cd 0.0S mr:r tn the whol: body cr 0.2.rrer to.
-any cr;;cn in : 21 day peried.
A n 92 d%
period wedd excccd j
2.5 ' m ce m 4c 036 W e'*
40 %
ictut heh any c ry s.
or APPLICABILITY: At all times.
I ACTION:
a.
With radioactive liquid waste being discharged without treatment and in excess of the above limits and any portion of the Liquid Radwaste Treatment System not in operation, prepare and submit to the Commission within 30 days pursuant to Specification 6.9.2, a Special Report that includes the following information:
1.
Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability, 2.
Action (s) taken to restore the inoperable equipment to OPERABLE status, and 3.
Summary description of action (s) taken to prevent a recurrence.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.11.1.3.1 Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.
4.11.1.3.2 The installed Liquid Radwaste Treatment System shall be considered OPERABLE by meeting Specifications 3.11.1.1 and 3.11.1.2.
WOLF CREEK - UNIT 1 3/4 11-6
SPEQFtCA%4 3. II,I.3 Justification:
l The above numbers are consistent with 3.11.1.2, and there is no need to further restrict operations since these are the part 50 Appendix I (ALARA) design goals, not part 20 (Rad Protection) limits.
In addition due to the recirculation of the Wolf Creek cooling lake, Wolf Creek cannot meet the lower values provided-in the standard RETS.
The ER(OLS) notes the calculated doses from operation of WCGS under normal conditions (Table 5.2-12) to be 2.5 mrem / year total body and 3.6 mrem /yr organ dose. These doses meet the ALARA criteria, but cannot meet the summarily lowered limits in the standard RETS.
RADIOACTIVE EFFLUENTS LIQUID HOLDUP TANKS LIMITING CONDITION FOR OPERATION 3,.11.1.4 The quantity of radioactive material contained in each of the following l
unprotected outdoor tanks shall be limited to less than or equal to 150 l
Curies, excluding tritium and dissolved or entrained noble gases.
a.
Reactor Makeup Water Storage Tank,
- b..e.
CondensateStorageTank,yind
,( os$ sa c..i<ds of cod =2 p'i'"l b b.
"; fueling '.'eter Storage Tenk, pu an-ic<A e )
3 e,-d.
Outs _ide temporary anks exch. ding 'iner: '; ing u::d t: ::lidify
. m _._.
'~
Ua J.ay as
%,_, % x 6"^h "' ' I.
xh.dh \\
Scr APPLICABILITY:
At all times.
rue.ivin$ rcAedvu ACTION:
a.
With the quantity of radioactive material in any of the above listed tanks exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limit, and describe the events leading to this condition in the next semiannual Radioactive Effluent Release Report, pursuant to Specification 6.9.1.7.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.11.1.4 The quantity of radioactive material contained in each of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents et 'e25t ence p"U'AA "7 days when radioactive materials ere bei g added to the tank.
Nve. been l
WOLF CREEK - UNIT 1 3/4 11-7
SPECIFICATION 3.11.1.4 JUSTIFICATIDN:
.(1) n.: ::lec44en. f 150 :::it: :: : t: h :: tivi:y 1*
't i: b::cd
.rpee e-!ruleti--e par #---
A
rr c~er 7 ----r e rejer,
+a r
a: directive tr9 supur4s-(FS*_" ?"PS Site ^dderd"- Section 2.4,12.1 : d 2 A.E3),- Rasults-of-tha-groundwater-transport-l calculatione-indi:: : that 150 curier is e w fficieetly - rli l
-fraction of th; tank ;;tivity levcle Icquired te exceed-MPC-l eensentraticer et the ---reet grered" ster discherge leesticer.
(2) The SNUPPS Plants have 3 permanent outside storage tanks which have the possibility of receiving radioactive materials:
a.
Refueling Water Storage Tank (RWST) (Ref: FSAR Section 6.3.2.2 and FSAR Table 3.2-1 (Sheet 5)).
Although the RWST has the greatest probability of con-taining significant levels of radioactivity, it is a Seismic Category I structure, with overflows to the liquid radwaste system. It should therefore be exempt from this Specification.
b.
Condensate Storage Tank (CST) (Ref: FSAR Section 9.2.6)
The CST is not a Seismically designed structure, but under normal operations, it will contain no radioactivity. Only in the event of a primary-to-secondary system leakage due to a steam generator tube leak, is it possible that the CST would contain radioactive materials. Therefore, the CST should be exempt from the sampling and analysis require-ments of this Specification until such time as it is possible for it to contain radioactive materials.
Reactor Makaup Storage Tank (RMWST) (FSAR Section 9.2.7.2.1 and c.
and FSAR Table 3.2-1 (Sheet 8)
The RMWST is not a Seicmically designed structure and, under normal operations, has the possibility of containing extremely low levels of radioactivity.
It should therefore be included as part of this Specification.
Modification of the LCO as proposed ensures applicability of the Specification to the SNUPPS Plant design, while maintaining the j
intent and purpose of the Specification.
1
Q)-ACTION-b-As-indicat ed-in-ACTION-a,-even t s-ex c ee d ing -the-LCO-are described-in-the-Semiannual-Radioactive-Efflueet
-Release-Report,-therefore,-Specif-icat-for. 6.9.1.ll-le-not applicab1 h (4) Surveillance Requirements 4.11.1.4 Due to the low level of activity available for addition to these tanks, a sample every 7 days is adequate if only additions have been made. The wording provided by the Standard Tech Specs would require a separate sample for each addition to the tank - no matter how small. This restriction is not warranted on these outside tanks.
I i
i
RADIOACTIVE EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION 4
3.11.2.5 The concentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be limited to less than or equal tof2fby volume whenever the hydrogen concentration exceeds 4% by volume.
/3.5%
APPLICABILITY: At all times.
ACTION:
- 3. 5%
a.
With the conc tration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than E by volume but less than or equal to 4% by volume, reduce the oxygen concentration to the above limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
b.
With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than 4% by volume and the hydrogen concentration greater than 4% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or l
equal to 4% by volume, then take ACTION a. above.
l c.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.11.2.5 The concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM shall be determined to be within the above limits by continuously monitoring the waste gases in the WASTE GAS HOLDUP SYSTEM with the hydrogen and oxygen monitors required OPERABLE by Table 3.3-13 of Specification 3.3.3.11.
WOLF CREEK - UNIT 1 3/4 11-15
SPECIFICATION 3.11.2.5 l
JUSTIFICATION:
The proposed substitution is designed to reflect the site spe;cific design of the SNUPPS Plant in that:
KThe hydrogen and oxygen monitoring instrumentation monitor the' of the recombiner,therefore thQnlet H2/02 and outlet H2/02 only the~
service Waste Gas Decay Tank is monit~ored with installed ins ntation.
.(b)
The SNUPPS Plant WASTE UP SYSTEM is designed with aIDecay Tanka.Ded-substitution allows only one of which can a total of eight Wast one time. The prop be in service a the opera e d f the system using one of the o hed tanks, while ry actions are being taken to reduce the oxygen' level nec N
the affected tank.
(q)
As described in FSAR Section 11.3.6, a minimum of 5 volume percent oxygen is required to support combustion of 4 volume percent hydrogen. The SNUPPS Plant System is designed for alarm at 3 volume percent oxygen and alarm and isolation of oxygen feedgas at 3 volume percent oxygen. These values are well below the necessary 5 volume percent oxygen and the Specification 3.11.2.5 limit of 4 volume percent oxvsen.
(4-)--
equirement to be within limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> la ACTI is inc tent with the requirements of ACTION b.
- tionally, in the even recombiner failure, it woul me necessary to vent the aff te tank to the atmo in order to be in compliance with the(Specif,ica Such an action could possibly result in a violar on, f Specification 3.11.2.2, 3.11.2.3, and 3Ar't'f. The propc, e(wording however, would afford t e.-op'erational lattitude to ventge tank slowly over er period and perhaps allow the utilization of more a o favorable meterology to reduce doses and dose rath 1
RADIOACTIVE EFFLUENTS GAS STORAGE TANKS LIMITING ' CONDITION FOR OPERATION 3.11.2.6 The quantity of radioactivity contained in each gas storage tank shall be limited to less than or equal to 7 x 10s Curies of noble gases (con-sidered as Xe-133 e-"*"e!ent).
2.5 APPLICABILITY
At all times.
ACTION:
a.
With the quantity of radioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the tank contents to within the limit, and describe the events leading to this condition in the next semianntal Radioactive Effluent Release Report, pursuant to Specification 6.9.1.7.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.11.2.C h-quantity of radioactive material contained in ameh g:: nuiage tank shall be determined to on : - tb: :.-= #1mit at least once per 24
- -G;wcu,1ve materials are being added to the T.ank.
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4.11.2.6.2 The quantity of radioactive material contained in the inservice Waste Gas Decay Tank shall be determined to be within the above limit at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when:
a.
Primary coolant system degassing operations are occurring, and b.
Conditions of confirmed 1% or greater failed fuel exist, and
- c. Radioactive materials have been added to the tank.
4.11.2.6.3 The quantity of radioactive material contained in the inservice Waste Gas Decay Tank shall be determined to be within the above limit at least once per 7 days when:
a.
Conditions of confirmed 1% or greater failed fuel exist, and b.
Radioactive materials have been added to the tank.
4.11.2.6.1 The quantity of radioactive materials contained in each Waste Gas Decay Tank shall be determined to be within the above limit at least once per 18 months during shutdown.
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SPECIFICATION 3.11.2.6 JUSTIFICATION:
(1)
Tank Content: NUREG 0133 (October 1978) Section 5.6.1 provides the following equation for determining the maximum curie limit in each gas stcrage tank:
Y#
I Q iT 10' pCi/Ci IKg (X/Q)DBA **** **"!"
7#)
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2.0 E-04 sec/ meter G211away) FSAR Table 15 A-2
'(X/Q)DBA
=
1.5 E-04 Wolf Creek)
=
FSAR Table 15.7-3 identifies Xe-133 (59%) and Kr-85 (36%)
as the principal activities assumed to be released in the event of a waste gas decay tank rupture.
t From Reg. Guide 1.109 Table B-1:
3 2.94 E +02 (mrem /yr) per (pCi/m )
Kg (Xe-133)
=
g (Kr-85) = 1.61 E + 01 K
IQ 2.5 E+05 Curies per tank (callaway) 1T j:,
3.3 E+05 Curies per tank (Wolf Creek)
FSAR_Section 11.3.2.1 states. " Operation of the system is such that fission gases are distributed throughout the six normal operation gas decay tanks. Seperation of the Gaseous Radwaste System gaseous inventory in several tanks assures that the allowable site boundry dose will not be exceeded in the event of a gas decay tank rupture."
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SPECIFICATION 3.11.2.6 JUSTIFICATION (Continued)
(2) Depending on operating conditions at the time, it may prove -
inadviseable to place restrictions on the length of time given to accomplish the activity reduction.
l The proposed wording allows the operator to assess the various parameters and to make a reasonable decision, balancing the risks involved (e.g.
excessive dose vs.
possibility of tank rupture).
The restriction to a finite time limitation could result in circumstances whereby the Specification is in direct oposition to the satisfaction of other Specification (s).
The proposed wording is also consistent with the proposed modification to Specification 3.11.2.5.
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SPECIFICATION 4.11.2.6 JUSTIFICATION:
FSAR Section 15.7.1 describes the analysis of a postulated I.
Waste Gas Decay Tank failure and its projected radiological This evaluation utilized the fission product.
consequences.
accumulation and release assumptions identified in Regulatory Guide 1.24.
Some of these assumptions are:
(a) The maximum amount of waste gases stored in any one tank occurs after a refueling shutdown, at which time the Waste Gas Decay Tanks store the radioactive gases stripped from the reactor collant.
(b) The accumlated activity in the gaseous waste processing system after 40 years' operation and immediately following plant shutdown (with zero decay) assumed to be in the Waste Gas Decay Tank, is based on 1% failed fuel, which is 8 times greater than that assumed under normal operating conditions.
All noble gas activity has been removed from the reactor coolant system and r.ransferred to the Waste Gas Decay Tank that is postulated to fail.
The calculated maximum activity in the Waste Gas Decay Tank under these conditions is presented in Table 15.7-3, and is approximately 2.1 E04 Curies.
The caluclaced whole body dose to an individual at the Exclusion A 2a Boundary (EAR) is presented in Table 15.7-4, and is 33 mrem (Callaway) and 25 mrem (wolf Creek).
From the aforementioned analysis, we can conservatively establish the following conclusions:
1.
The maximum amount of activity in a Waste Gas Decay Tank during normal operations is the result of primary system degassing operations.
The maximum amount of activity in the primary collant system, and 2.
thus the Waste Gas Decay Tank, occurs during periods of 1% or greater failed fuel.
l The maximum Waste Gas Decay Tank activity, after 40 years of operation i
3.
with 1% failed fuel and immediately following total primary coolant system degassing, is conservatively estimated as approximately 8% of the limit calculated using NUREG 0133 methodology.
The projected whole body dose to an individual at the EAB, using 4.
the limiting short-term X/Q, is conservately estimated as approximately 7% of the 500 mrem NUREG 0133 objective and approximately 1% of the 10 CFR 100.11 limit.
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5.
Due to the relatively low smount of activity available to be added to the Waste Gas Decay Tank under normal operations, sampling is unwarranted until such time as the condition of 1% failed fuel is, encountered.
II. It is the expressed purpose of 10CFR20 (10CFR20.l(c)) that radiation exposures and releases of radioactive materials in effluents to un-restricted areas be maintained ALARA. It is not in keeping with the concept of ALARA to require sampling and analysis activities which result in unnecessary occupational radiation exposure and releases of radioactive materials to the environment.
The preposed sampling and analysis requirenents serve to implement good ALARA principles and thus reduce the expended man-rem, both occupationally and to the public.
III. The intent of Specification 3.11.2.6 as stated in the Bases, is to provide assurance that in the event of an uncontrolled release of the Waste Gas Decay Tank's contents, the resulting whole body dose to an individual at the nearest EAB will not exceed 500 mrem, which is substantially below the dose li=1ts of 10CFR 100 for a postulated event.
The analysis of a postulated Waste Gas Decay Tank repture, conducted in accordance with Nuclear Regulatory Commission Guidelines and recce=endations, using greatly conservative assumptions, conclusively demonstrates that the proposed surveillance requirements maintain a significant margin of safety with respect to the expressed objective of Specification 3.11.2.6 thus assuring that the limits of 10CFR 100 are not approached.
l
RADIOACTIVE EFFLUENTS BASES requirement that the appropriate portions of this system be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objectives given in Section II.D of Appendix I to 10 CFR Part 50.
The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.
This specification applies to the release of radioactive material gs gaseou ifluents from each unit at the site. When shared Radwa e-Treatment Systems are lisTd-by more than one unit on a site, the was all units are mixedforsharedtreatment;,3peciQcunit.
by sucn mixing, the effl eleases cannot accurately be ascribed to a A
imate should be made of the contributions from each unit based o conditions, e.g., flow rates and radioactivity concentrations, or not pheticable, the treated effluent releases may be allocat jed ly to each of the Fadioactive waste producing unitssharingtheJadwisteTreatmentSystem.
For oetermiritqformance to LCOs, thes jetrcations from shared Radwaste Treatment Systems are7 e added to pthTeases specifically attributed to each unit to obtain the total releases per unit.
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p 3/4.11.2._5 EXPLOSIVE GAS MIXTURE o.
I This specification is providea to ensure that the concentration / of potentially explosive gas mixtures contained in the WASTE GAS HO)0'UP SYSTEM is
.4 maintained below the flammability limits of ydrogen and oxygen (.
(Automatic e'
control features are included in the system to prevent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of hydregen and/or oxygen l)
,autc=atie-diversien te rccomoiners;-cr inject 4cn cf dilutant: to reduce-the-
-consente.icn belet the #10-" abi'ity '"its. ) Maintaining the concentratien of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the'ryquirements Gf General Design Criterion 60 of Appendix A to 10 CFR Part. 53.
~~
3/4.75.2.6 GAS STORAGE TANKS The tanks inc7aded in this specification are those tanks for which the quantity of radiontivity contained is not limited directly or indirectly by another Technical Specification to a quantity that is less than the quantity that provides assurance that in the event of an uncontrolled release of the J.anks' contenti~, tae resulting whole body exposure to a MEMBER OF THE PUBLIC
~ ' at the. nearest SITD BOUNDA.SY will not exceed 0.5 rem, the annual dose limit in 10 CFR P<u t 20.
s 3
ResO icting.the quantity,of radioactivity contained in each gas storage tank provides assurance that b the event of an uncontrolled release of the tank's contents, che resulting whole body exposure to a MEMBER OF THE PUBLIC at the nearest SITE BOUNDARY vill not exceed 0.5 rem. This is consistent with WOLF CREEK J U E T 1 B 3/4 11-6 i
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1 B3/4.11.2.5 JUSTIFICATION Since Specification 3.11.2.5 does not require automatic control features on the Waste Gas Hold Up System, the indicated portion was deleted as not applicable.
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s RADIOACTIVE EFFLUENTS BASES GAS STORAGE TANKS (Continued)
Standard Review Plan 11.3, Branch Technical Position ETSB 11-5, " Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure," in NUREG-0800, July 1981,and N Fsv-eident ana.npts a.
ude. wh iht RArc y
3/4.11.3 SOLID RADI0 ACTIVE WASTES This specification implements the requirements of 10 CFR 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establishing the PROCESS CONTROL PROGRAM may include, but are not limited to waste type, waste pH, waste / liquid / SOLIDIFICATION agent / catalyst ratios, waste oil content, waste principal chemical constituents. and mixing and curing times.
3/4.11.4 TOTAL DOSE This specification is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The specification requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and the radiation T
from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ,
-)
except the thyroid, which shall be limited to less than or equal to 75 mrems.
For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix I, and if direct radiation doses from the reactor units and from outside storage tanks are kept small. The Special Report will describc & course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to, the MEMBER OF,,
~"
THE PUBLIC from cther uranium fuel cycle sources is negligible', with'the exception that dose contributions from other nuclear fuel cycle facilities at the same site.or.within,4.. radius of 8 km must be consi.dered,, If the dose, Ao. -
any MEMBER OF THE PUBLIC is estimated to exceed the requirements of'40 CFR' '
'u' Part 190, the Special Report with a request for a variance (provided the release conditions resulting--in-violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 and 10 CFR 20.405c, is considered to be a timely request and fulfills the require-ments of 40 CFR Part 190 until NRC staff action is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in Specifications 3.11.1.1 and 3.11.2.1.
An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.
WOLF CREEK - UNIT 1 B 3/4 11-7
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-Insert The contents of these tanks shall be determined at least once per 18 months during shutdown. However, should conditions of confirmed 1% or greater failed fuel exist, the -tank contents will be detennined at a frequency consistent with Specifications 4.11.2.6.2 cr-4.11.2.6.3.
f 5
l I
4
9 8 3/4. 11.2.6 JUST1FICATION This bases has been revised to be consistent with the sampling methodology in Specification 4.11.2.6.