ML20154C346

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Forwards Draft Input to SER Re Util 871001 Request to Change Tech Specs Concerning Monitoring of Radioactive Effluents. Use of Addl Monitors to Fulfill Tech Spec Requirements for Monitoring Particulates & Noble Gases Unacceptable
ML20154C346
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 05/04/1988
From: Heiter K
Office of Nuclear Reactor Regulation
To: Robert Williams
PUBLIC SERVICE CO. OF COLORADO
References
EA-88-069, EA-88-69, TAC-66505, NUDOCS 8805180124
Download: ML20154C346 (6)


Text

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May 4,1988 Docket No.:

50-267 EA NO.

(88-69)

Mr. R. O. Williams, Jr Vice President, Nuclear Operations Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201-0040

Dear Mr. Williams:

SUBJECT:

FORT ST. VRAIN RADI0 ACTIVITY EFFLUENT MONITORS (TAC NO. 66505)

The staff has completed its review of the Public Service Company of Colorado's setmittal dated October 1, 1987 requesting changes in Technical Specifications (TS) regarding monitoring of radioactive effluents. This review also considered supplerental inferration that was submitted in a letter dated February 15, loEE.

The prepcsed arendnent would:

(1) allev you to use additional mcnitors to fulfill TS recuirements for monitoring particulates, halogens, and noble gases; (2) require under some circurstances that you repair inoperable monitors within 7 days, rather than 30 days; (3) clarify when a gamma spectral analysis will be perforred on sarrples taker from the gas waste tank; and (4) correct an error in Envircrrental Surveillance Requirement 8.1.F.

The enclosed draft irput to the Safety Evaluation Report concludes that Item I is unacceptable for the reasons ncted in the report.

Items 2, 3 and 4 meet the applicable regulatory guidance and requirerents and are therefore acceptable.

The deficiencies of your proposal have been discussed with Mr. M. Holres of your staff. The staff can reconsider your preposals if the following requirements are included.

A requirenent to check the additional particulate and halogen monitors (RT a801 and 4802) every four hours, when these are the only operable monitors.

A requirement to check the additional noble gas monito" (RT 4003) every four hours, when it is the only operable monitor. Also, the additional noble gas ronitor coul.1 only be utilized in this mede for a 30 day period.

Please provide your respense to this draft Safety Evaluation input within 60 days of the date of this letter.

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2-The information requested in this letter affects fewer than 10 respondents;

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j therefore OMB clearance is net required under P.L. 96 511.

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4 Kenneth L. Heitner, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation 1

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4 R. O. Williams, Jr. L The information requested in this letter affects fewer than 10 respondentst therefore OMB clearance is not required under P.L.96-511.

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Project Directorate - iV Division of Reactor Projects - III.

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Public Service Company of Colorado Fort St. Vrain cC' Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201-0840 Mr. David Alberstein, 14/159A Mr. R. O. Williams, Jr., Acting Manager GA Technologies, Inc.

Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Public Service Company of Colorado Denver, Colorado 80201-0840 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector U.S. Nuclear Regulatnry Comission Mr. R. F. Walker P. O. Bnx 640 Public Service Corpany of Colorado Platteville, Colorado 80651 Post Office Box 840 Denver, Colorado 80201-0840 relley, St!insfield & 0'Donnell Public Service Company Building Comitment Control Program Room 900 Ceordinator 550 15th Street Public Service Company of Colorado Denver, Colorado 80202 2420 W. 26th Ave. Suite 100-D Denver, Colorado 80211 Regional Administrator, Region IV U.S. Nuclear Regulatory Comission 611 Pyan Plaza Drive. Suite 1000 Arlington, Texas 76011 Chairman, Board of County Cemissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Padiation Progrras Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver, Colorado 80202-?413

a ENCLOSURE 1 RADIATION PROTECTION BRANCH'S INPUT TO SAFETY EVALUATION REGARDING FORT ST. VRAIN RADI0 ACTIVE EFFLUENT MONITORS DOCKET NO. 50-267

1.0 INTRODUCTION

By letter dated October 1, 1087, Public Service Company of Colorado, the licensee for Fort St. Vrain Nuclear Generating Station, requested a license amendment to revise their Technical Specifications (TS) (Ref.1).

In response to an NRC staff request, supplemental information was submitted in a letter dated February 15, 1988 (Ref. 2). The amendment concerns the monitoring cf radioactive effluents at Fort St. Vrain.

The proposed amendment would:

(1) allow the licensee to use additional meni-tors (RT-4801, RT-4802, and RT-4803) te fulfill the TS requirements for moni-toring particulates, halogens, and noble gases, respectively; (2) require the licensee under some circumstances to repair inoperable monitors within 7 days, rather than 30 days; (3) clarify when a garra spectral analysis will be per-forred on serples taken from the gas waste tank; and (4) correct an error in Environrental Surveillance Requirement (ESR) 8.1.2, note 4 (pace 8.1-24).

2.0 EVALUATION Item 1 - Additional Monitors Environrental limiting Condition of Operation (ELCO) 8.1.1.g.2 (page 8.1-3) currently requires that if the halogen or the particulate monitor becomes inoperable, gaseous effluents may continue to be released from the reactor building ventilation system provided that the effluent is continuously mont-tored with auxiliary sampling equipment. The licensee has proposed amending this ELCO to state that the monitor referenced in the ELCO is "the required monitor," and that if "the required monitor" is not available, then sanples shall be obtained at least once per seven days and analyzed vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The effect of this change (and a corre.sponding change to ESR 8.1.1, note, page i

8.1-9) would be to allow the licensee to indefinitely use monitors (RT-4P01 and 4807) that would alarm at a "local" location, rather than alarm in the control l

rovm, as the required monitors (see Attachinent 1 of Ref. ?). The monitors that presently serve this function are required to alarm in the control room.

The staff finds tre proposed change unacceptable because if the additional ronitors (RT-4801 and 4802) failed to operate, tFe failure would not be known until someone checked tne local alarm location. The licensee notes that this area is currently checked every four hours (Ref. 1. Attachment 4, page 3 );

however, the TSs do not require this surveillance.

t ELCO 8.1.1.g.3 (page 8.1-4) currently reovires that if both noble gas monitors beccme inoperable, gasecus effluents may continue to be released from the reactor building ventilation system provided that grab samples are taken at least nnce per eight hours and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee has proposed amending the ELCO (and also ELCO E.1.1.g 4) to state that the monitor referenced in the ELCO is "the required monitor." The effect of this change 4

4

(and a corre'sponding change to ESR 8.1.1, note, page 8.1-9) is similar to the effect'for the halogen and particulate monitors.

The change would allow the licensee to indefinitely use a monitor (RT-4803) with a "local" alam, rather than an alarm in the control room, as one of the required monitors (see Attach-ment 1 of Ref. 2).

In contrast to the two exisiting monitors (RT-7324-1 and 2), the added monitor is not capable of teminating releases from the reactor building vent.

The staff finds the proposed change unacceptable for the reasons noted in regard to the halogen and particulate monitors, and clso because the added ronitor does not have the capability to terminate releases.

Item 2 - Inoperable Monitors ELCO 8.1.1.g.8 (page 8.1-6) currently requires that if one or more of the gaseous effluent roniters are inoperable, "best efforts shall be exerted to return the instruments to operable status within thiry days, and if unsuccess-ful," provide an explanation in the next Semi-Annual Effluent Report. The licensee has proposed amending the TS to exert "best efforts" to return the instruments to operable status within seven days and if unsuccessful, to subnit a special report withir 14 days. The staff finds the proposed change acceptable.

Item 3 - Garra Spectral Analysis The licensee proposes to charge ESR 8.1.1.1.d (page 8.1-10) to clarify when a gama spectral analysis shall be perfomed on samples taken from the gas waste tank. The licensee proposes to analyze the sanples within 40 hcurs. The staff finds this change acceptable since it is consistent with the standard technical specifications.

Item 4 - Correctior.

The licensee proposes to delete ESR 8.1.2.d 4 (page 8.1-24) since it is not applicable to the instrument controls at Fort St. Vrain. The staff finds this change acceptable.

3.0 CONCLUSION

S The staff has reviewed Public Service Company of Colorado's proposed amendment regarding the monitoring of radioactive effluents at Fort St. Vrain. The staff finds Item 1 unacceptable for the reasons noted in the report.

The staff finds that Items 2, 3 and 4 meet the applicable regulatory guidance and requirements and are therefore acceptable.

Principal Contributor:

Edward F. Branagan, Jr.

4.0 REFERENCES

1.

Letter from R. O. Williams, Jr., Public Service Company of Colorado, to Nuclear Regulatory Comission, dated October 1,1987.

2.

Letter from R. O. Williams, Jr., Public Service Company of Colorado, to j

Nuclear Regulatory Comission, dated February 15, 1988.

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