ML20151G237

Proposed Tech Specs,Revising RCS Iodine Activity Limits & Surveillance Requirements

ML20151G237
Person / Time
Site:	Oyster Creek
Issue date:	04/05/1988
From:	GENERAL PUBLIC UTILITIES CORP.
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Shared Package
ML20151G229	List: ML20151G227 ML20151G237 ML20151G287
References
NUDOCS 8804190296
Download: ML20151G237 (10)

Text

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I TABLE OF CONTENTS Section 1 Definitions Page 1.1

- 0perable

1. 0-1 1.2 Operating

1. 0-1 1.3 Power Operation

1. 0-1 1.4 Startup Mode

1. 0-1 1.5 Run Mode

1. 0-1 1.6 Shutdown Condition

1. 0-1 1.7 Cold Shutdown 1.0-2 1.8 Place in Shutdown Condition 1.0-2 1.9 Place in Cold Shutdown Condition 1.0-2 1.10 Place in Isolated Condition 1.0-2 1.11 Refuel Mode 1.0-2 1.12 Refueling Outage 1.0-2 1.13 Primary Containment Integrity 1.0-2 1.14 Secondary Containment Integrity 1.0-2 1.15 Deleted 1.0-3 1.16 Rated Flux 1.0-3 1.17 Reactor Thennal Power-To-Water 1.0-3 1.18 Protective Instrumentation Logic Definitions 1.0-3 1.19 Instrumentation Surveillance Definitions 1.0-4 1.20 FDSAR 1.0-4 1. 21 Core Alteration 1.0-4 1.22 Minimum Critical Power Ratio 1.0-4 1.23 Staggered Test Basis 1.0-4 1.24 Surveri

. Requirements 1.0-5 1.25 Fire V aion Water System 1.0-5 1.26 Fra w i i.imiting Power Density (FLPD) 1.0-5 Maxiinum Fraction of Limiting) Power Density (MFLPD) 1.27 1.0-5 Fraction of Rated Power (FRP 1.0-5 1.28 1,29 Top of Active Fuel (TAF) 1.0-5 1.30 Reportable Event 1.0-5

1. 31 Identified Leakage 1.0-6 1,32 Unidentified Leakage 1.0-6 i

1.33 Process Control Plan 1.0-6 1.34 Augmented Offgas System (A0G) 1.0-6 1.35 Member of the Public 1.0-6 1.36 Offsite Dose Calculation Manual 1.0-6 1.37 Purge 1.0-6 1.38 Exclusion Area 1.0-6 1.39 Dose Equivalent I-131 1.0-7 l

Section 2 Safety Limits and Limiting Safety System Settings 2.1 Safety Limit - Fuel Cladding Integrity 2.1 -1 2.2 Safety Limit - Reactor Coolant System Pressure

2. 2-1 2.3 Limiting Safety System Settings 2.2-3 Section 3 Limiting Conditions for Operation 3.0 Limiting Conditions for Operation (General)

3. 0-1 3.1 Protective Instrumentation 3.1 -1 0YSTER CREEX i

Amendnent No. :

64, 84, 97, 108 8804190296 880405 DR ADOCK 0500 9

1.39 DOSE EQUIVALENT I-131 C

DOSE EQUIVALENT I-131 shall be that concentration of I-131 microcuries per gram which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present.

The thyroid dose conversion factors used for this calculation shall be those listed in Table E-7 of Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluences for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I".

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a OYSTER CREEK 1.0-7 5364g i

3.6 Radioactive Effluents Applicability: Applies to the radioactive effluents of the facility.

Objective: To assure that radicactive material is not released to the environment in an uncontrolled manner and to assure that the radioactive concentrations of any material released is kept as low as is reasonably achievable and, in any event, within the limits of 10 CFR part 20.106 and 40 CFR Part 190.10(a).

Specification 3.6.A.

Reactor Coolant Radioactivity The specific activity of the primary coolant except during REFUEL MODE shall be limited to: Less than or equal to 0.2 microcuries per gram DOSE EQUIVALENT (D.E. ) I-131.

Limiting Condition for Operation 1.

Whenever an isotopic analysis shows reactor coolant activity exceeds 0.2 uCi/ gram DOSE EQUIVALENT (D.E.) I-131, operation may continue for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Additional analyses shall be done at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> until the specific activity of the primary coolant is restored to within its limit.

2.

If the reactor coolant activity is greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous i

time interval or greater than 4.0 microcuries a

per gram D.E. I-131, be in at least SHUTDOWN CONDITION within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3.

Annual Reporting Requirement The results of specific activity analyses in which the reactor coolant exceeded the limits l

of Specification 3.6. A shall be reported on an l

annual basis.

The following infonnation shall be included:

(1) Reactor power history l

starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded until after the l

radioiodine activity is reduced to less than l

the limit; (2) Results of the last isotopic analysis for radiof odine performed prior to exceeding the limit, results of analysis while OYSTER CREEK 3.6-la Amendment No.:

48, 108 53649

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['U limit was exceeded and results of one analysis after radiofodine activity was. reduced to less than the limit.

Each result should include date and time of sampling and the radiofodine

.3 coticentrations; (3) Clean-up system flow y.

F history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first

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scople in which the limit was exceeded ur.,,11 after the radiotodine activity is reduced to less than the limit; (4) Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radiof odine !imit.

4.

With the reactor mode switch in Run or Startup position, with:

1.

Thermal power changed by more than 15% of rated thennal power in one hour *, or a

2.

The off-gas level, at the SJAE, increased by more than 10,000 microcuries per second i

in one hour during steady state operation at release rates less than 75,000 microcuries per second, or 3.

The off-gas level, at the SJAE, increased by more than 15% in one hour during steady state operation at release rates greater than 75,000 microcuries per second, take sample and analyze at least one sample, between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the change in thermal power or off-gas level and at least once per four hours thereafter, until the specific activity of the primary coolant is restored to within limits.

3.6.B Liquid Radwaste Treatment Applicability:

To liquid radwaste batches before discharge as aqueous effluent.

• If there are consecutive thermal power changes by more than 15% per hour, take sample and analyze at least one sample between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the change and at least once per four hours thereafter, until the specific activity of the primary voolant is restored to within limits.

0YSTER CREEK 3.6-lb Anendnent No. : 49, 108 5364g I

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Basis:

3.6.A 10CFR100, as implemented by SRP Section 15.6.4, requires that the. radiological consequences of,

failure of a main steam line outside containment be limited to small fractions of the exposure guidelines of 10CFR100.

During Systematic Evaluation Program (SEP) for Oyster' Creek, an independent assessment of the radiological consequences of a main steam line failure outside containment (SEP Topic XV-18) was performed by the NRC staff.

The assessment determined that if the existing Oyster Creek Technical. Specification'11mit for primary coolant iodine activity (8.0 uCi total iodine per gram) is used, the potential offsite doses would exceed the applicable dose limit.

The staff recomended that Oyster Creek maintain the primary coolant radioiodine activity within the General Electric Standard Technical Specification (NUREG-0123) limit (0.2 uCi/ gram DOSE EQUIVALENT I-131), which would meet the acceptance criteria.

However, the Staff's analyses for Oyster Creek showed that small-line failures are more limiting than the main steam line failure. -10CFR100, as implemented by SRP Section 15.6.2, requires that the radiological consequences of failure of small lines carrying primary coolant outside containment be limited to small fractions of the exposure guidelines of 10CFR100.

During the evaluation of SEP Topic XV-16 "Radiological Consequences of Failure of Small Lines Carrying Primary Coolant

'Outside Containment" the Staff determined that Oyster Creek does not comply with current acceptance criteria.

The Staff recommended that the General Electric Standard Technical Specification (NUREG-0123) limit (0.2 uCi/ gram DOSE EQUIVALENT I-131) for reactor coolant radioiodine activity be adopted in order to ensure that the radiological consequences to the environment from a failure of small lines are acceptably low.

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OYSTER CREEK 3.6-7a Amendment No.:

49, 108 3

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The LC0 statement pennitting power operation to continue for limited time periods with the primary coolant's specific activity greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131, ~but less than or equal to 4.0 microcuries per gram DOSE EQUIVALENT I-131, accomodates possible iodine spiking phenomenon which may occur following changes in thermal power..The reporting of cumulative operating time with greater than 0.2 microcuries per gram DOSE EQUIVALENT I-131 will allow sufficient time for Comission to evaluate the circumstances.

Information obtained on iodine spiking will be used to assess the parameters associated with spiking phenomena.

A reduction in frequency of isotopic analysis following power changes may be permissible if justified by the data obtained.

The surveillance requirements provide adequate assurance that excessive specific activity levels in the reactor coolant will be detected in sufficient time to take corrective action.

3.6.B This specification implements the requirements of 10 CFR 50.36a related to operation of radioactive waste treatment equipment to keep radioactive material in effluents to unrestricted areas as low as reasonably achievable.

Radioactive liquid wastes generated at the OCNGS are controlled on a batch basis with each batch processed by a method appropriate for the quality and concentration of material present.

Below 0.001 uCi/m1, it is not cost-beneficial to treat a batch of aqueous waste for the purpose of reducing potential radiation exposure offsite.

Hence specification 3.6.B implements 10 CFR Part 50 Appendix I provisions for cost-beneficial treatment of radioactive liquid waste before release in effluent.

Each batch of radioactive liquid waste is sampled and analyzed for radioactivity before release to the discharge canal so that an appropriate discharge rate can be determined, accounting for dilution by condenser cooling water and/or canal flow.

0YSTER CREEK 3.6-7b Amendment No.:

49, 108 4

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4.6 RADI0 ACTIVE EFFLUENT Applicability: Applies to monitoring of gaseous and liquid radioactive effluents of the Station during release of effluents via the monitored pathway (s).

Each Surveillance Requirement applies whenever the corresponding Specification is applicable-unless otherwise stated in an individual Surveillance Requirement.. Surveillance Requirements do not have to be performed on inoperable equipment.

Objective To measure radioactive effluents adequately to verify that radioactive effluents are as low as is reasonable achievable and within the limit of 10 CFR Part 20.106.

Speci fication:

A.

Reactor Coolant Reactor coolant shall be sampled and analyzed at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for DOSE EQUIVALENT I-131 during RUN MODE, STARTUP MODE and SHUTDOWN CONDITION.

B.

(See 4.6.I)

C.

Radioactive Liquid Storage 1.

Liquids contained in the following tanks shall be sampled and analyzed for radioactivity at least once per 7 days when radioactive liquid is being added to the tank:

a.

Waste Surge Tank, HP-T-3; b.

Condensate Storage Tank.

D.

Main Condenser Offgas Treatment 1.

Operation of the Offgas System charcoal absorbers shall be verified by verifying the A0G System bypass valve (V-7-31) alignment or alignment indication closed at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the main condenser air ejector is operating.

E.

Main Condenser Offgas Radioactivity 1.

The gross radioactivity in fission gases discharged from the main condenser air ejector shall be measured by sampling and analyzing the gases.

a.

at least once per month, and b.

When the reactor is operating at more than 40 percent of rated power, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after an increase in the fission gas release via the air ejector of more than 50 percent, as indicated by the Condenser Air Ejector Offgas Radioactivity Monitor after factoring out increase (s) due to change (s) in the thermal power level.

OYSTER CREEK

4. 6-1 Amendment No.:

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OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 00CKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO.148 REV.1 Pursuant to 10 CFR 50.91, an analysis concerning significant hazards considerations is provided below:

1.

Sections to be changed:

Table of Contents, 1.39 and 1.40, sections:

3.6 and 4.6.

2.

Extent of~ changes:

To incorporate radioiodine limits in reactor coolant system, appropriate limiting conditions for operation and sampling and analysis reauirements for iodine following changes in thermal power or offgas level as shown in Standard Technical Specifications for General Electric Boiling Water Reactors (NUREG-0123). Also to incorporate reporting reauirements for radioiodine spiking as shown in NRC Generic Letter 85-19, "Reporting Reauirement on Primary Coolant Iodine Spikes" and provide definitions for DOSE EQUIVALENT I-131 and HOT SHUTOOWN.

3.

Changes Reauested The reauested changes are shown on attacned Technical Specification pages i,1.0-7, 3.6-la, 3.6-1b, 3.6-7a, 3.6-7b, and 4.6-1.

4.

Discussion:

On October 23, 1986, GPUN submitted Technical Specification Change Reauest (TSCR) No. 148.

The TSCR No. 148 proposed changes to sections 3.6 and 4.6 concerning reactor coolant system (RCS) radioiodine activity limits and surveillance reauirements.

It also included definition for DOSE EQUIVALENT (0.E.) Iodine I-131 and annual reporting reauirement for radioiodine spiking.

These changes were proposed following discussions with the NRC staff during the integrated assessment of the Systematic Evaluation Program (SEP) for Topic XV-16, "Radiological Conseauences of i

Failure of Small Lines Carrying Primary Coolant Outside Containment" (IPSAR Section 4.36) and Topic XV-18, "Radiological Conseauences of a Main Steam Line Failure Outside Containment" (IPSAR Section 4.37).

The proposed changes in TSCR 148 in general reflected provisions given in Standard Technical Specifications for General Electric j

Boiling Water Reactors (NUREG-0123) and NRC Generic Letter 85-19, l

"Reporting Reauirement on Primary Coolant Iodine Spikes".

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Subseauently, the staff requested re-submittal of the proposed changes with the following revisions:

1)

Delete words "if. inhaled by an adult" from the definition of DOSE EQUIVALENT (D.E.) 1-131.

2)

Incorporate provisions for performing additional analyses at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> until restoration when the coolant activity exceeds 0.2 uCi/ gram 0.E.1-131.

3)

Eliminate provisions for allowing a second sample, and place the reactor in hot. shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the coolant activity exceeds 4 uCi/ gram D.E. 1-131.

4)

Add sampling and analysis reauirements for iodine following changes in thermal power or offgas level.

Above revisions were reauested by the staff to be consistent with Standard Technical Specifications for General Electric Boiling Water Reactors (NUREG-0123).

TSCR 148, Rev. 1, therefore has been prepared in response to the reauest by the staff described above.

This change request provides definitions, limiting conditions for operation, surveillance, annual reporting reauirement and sampling and analyses reautrement to incorporate Standard Technical Specifications for General Electric Boiling water Reactors (NUREG-0123) and NRC Generic Letter 85-19, "Reporting Reauirement on Primary Coolant Iodine Spikes".

We have determined that this change request involves no significant hazards considerations in that operation of the Oyster Creek Plant in accordance with the proposed amendment will not:

1.

Involve a significant increase in the probability of an accident previously evaluated, because the primary coolant activity is nut an initiator of an accident. Also, the proposed change will not increase the consecuences of an accident, because the proposed change, a reduction of the primary coolant activity limit, will not result in increased amount of radioactive release for design basis accidents previously evaluated; or 2.

Create the probability of a new or different kind of accident from any accident previously evaluated because a bounding design basis accident associated with changes in the primary coolant activity level was already evaluated and reported in FSAR (i.e., Control Rod Drop Accident); or 3.

Involve a significant reduction in a margin of safety because more restrictive limit for the primary coolant radio-iodine activity will increase a margin of safety.

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