ML20101C280

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Forwards Background Summary of Proposed Revs to Tech Specs Re Activity Monitoring Methods to Be Used During Liquid Effluent Releases from Reactor Bldg Sump.Proposed Revs Will Be Submitted by 841231
ML20101C280
Person / Time
Site: Fort Saint Vrain 
Issue date: 11/30/1984
From: Brey H
PUBLIC SERVICE CO. OF COLORADO
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-84510, NUDOCS 8412210021
Download: ML20101C280 (4)


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u Public Service Company F Cdlendo November 30, 1984 Fort St. Vrain Unit No. 1 P-84510 Regional Administrator

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Attn: Mr. E. H. Johnson

SUBJECT:

Technical Specification Revisions to ELC0 8.1.2, ESR 8.1.2 and ELC0 8.

1.3 REFERENCES

1.) NRC Letter dated August 31, 1984 (G-84329) 2.) PSC Letter from Gahm to Collins dated September 27, 1984 (P-84387)

Dear Mr. Johnson:

In Reference 2, Public Service Company of Colorado (PSC) states a revision to ELCO 8.1.3 will be made to delineate the type of activity monitoring which will be utilized during liquid effluent releases from the reactor building sump, and that this revision will be submitted by November 30, 1984.

This change has been prepared and is ready for submittal to the NRC, but since its preparation, ELC0 8.1.2 and ESR 8.1.2 have been found to require similar changes. Therefore, PSC will submit the proposed revision to ELC0 8.1.2, ESR 8.1.2 and ELC0 8.1.3 by December 31, 1984.

Additional time is required to route ELC0 8.1.2 and ESR 8.1.2 through the approval process.

l Attached is a background summary of the proposed revisions.

Included in this summary are descriptions of the July 19 and 20,1984

incident, current technical specification requirements, and preventative measures being taken to preclude future incidents of this nature.

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If you h' ave' any : questidns or comments on this matter, please contact Mr. M. H. Holmes at (303) 571-8409.

Very truly yours,

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H. L. Brey, Executive Staff Assistant Electric Production SBH/sem Attachment w,,,

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Attachm:nt s

to P-84510 ELC0 8.1.2, ESR 8.1.2 and ELC0 8.1.3 REVISION SUfEARY Introduction buring a greater than 10 gallon per minute (gpm) release from the Reactor Building Sump on July 19 and 20, 1984, the 10CFR20 limit on unknown radionuclides was exceeded. 'Se release was continuously monitored by two gama activity moni srs, which, on high gamma

activity, would have terminated the release automatically. However, since the radionuclide was a beta emitter, the release was not automatically terminated.

Source (s) of Beta Emitter The source of the beta emitter (sulfur 35) is identical to the source of the tritium also found in the Reactor Building Sump.

The source of the activity in this incident has been identified as the Helium Regeneration Compressor.

During maintenance on this piece of equipment, contaminated water was sent down the floor drain below the compressor to, as then believed, the Liquid Waste System. However, this drain actually went directly to the Reactor Building Sump.

Present Release Methods ELC0 8.1.3 provides for effluent releases directly from the Reactor Building Sump.

For releases from this sump, the flow from the Reactor Building Sump must be less than 10 gpm when operated in the automatic mode. At flow rates greater then 10 gpm, two grab samples shall be taken and analyzed prior to beginning the discharge. During the release, the pump outlet shall be contint.ausly sampled, and an analysis of the sample shall be performed as soon as practical. Daily samples from the Reactor Building Sump are taken and analyzed if the continuous sampler is inoperable, and this daily sample is how the beta emitter was discovered. No release from the Liquid Waste System may cake place during a Reactor Building Sump release, and releases from the Reactor Building Sump shall be continuously monitored by two gama activity monitors and their associated recorder.

Should one or both of the gama activity monitors become inoperable, releases may continue provided grab samples are taken every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzed for gama emitters, I-131 and tritium. The associated recorder may be inoperable during releases provided the count rate of each operable activity monitor is rcccrded at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ELCO 8.1.2 prcvides for releases from the Liquid Waste System, during which the same gama activity monitors are used.

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.q,:.C Attachm2nt t3 P-84510 o

Activity Monitors Gamma

- Currently, the activity monitors referenced in ELCO 8.1.2, ESR 8.1.2 and ELC0 8.1.3 do not identify the activity.

monitored.

These' monitors are gama activity monitors, and the revision of this section will clarify.this.

Beta Public Service Company of Colorado (PSC) has conducted an extensive search for an on-line beta activity monitor, and has detemined that no such instrumentation exists.

Prevention of Future Incidents The existing requirements for releases from the Reactor Building Sump will remain in effect.

Additional projects underway to minimize the possibility of recurrence of such a release include:

1)

The floor drains from the Regeneration Pump pit will be rerouted from the Reactor Building Sump to the Liquid Waste System.

This will be done under a change notice.

Currently, these drains are mechanically plugged.

2)

There is currently a project underway to map all the drains in the Reactor Building from their origin to their temination.

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The known sources of beta emitters throughout the Reactor Building will be identified, and then compared with the drain map to insure all known sources of beta emitters go directly to the Liquid Waste ~ System.

Should any beta emitter' sources not be properly routed, design changes shall be initiated to correct this situation.

Conclusion This revision of ELC0 8.l.2, ESR 8.1.2 and ELC0 8.1.3 does not-alter the method in which the system has been operated in the past.

It clarifies ~ the ty)e of monitors which.are used to monitor liquid releases from t1e Reactor Building Sump.

There should be no recurrence s ' this type of incident when the drain mapping-and rerouting programs are complete.

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