ML20154H818

Proposed Tech Specs Supporting Changes to Plant Rets,App B

ML20154H818
Person / Time
Site:	FitzPatrick
Issue date:	05/19/1988
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20154H703	List: JPN-88-021, Forwards Application for Amend to License DPR-59,clarifying & Correcting Minor Problems Noted in Rets,App B & Tech Specs App A.Fee Paid ML20154H706 ML20154H818
References
NUDOCS 8805260077
Download: ML20154H818 (29)

Text

_ _ _ _ _ _ _ . _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

s f- ,8

[. Table-2.1-1

.p c

/- ' i RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION l'

4 Minimum i Channels .

Ir_strument Operable Action Gross radioactivity monitors providing alarm and-automatic termination of release Liquid radwaste effluent line 1 (a)

Gross beta or gamma radioactivity monitors providing alarm but not providing automatic termination of release Service water system effluent line 1 (b)

Flow rate measurement devices Liquid radwaste effluent line 1 (c)

NOTES FOR TABLE 2.1-1 (a) With the number of operable channels less than the required minimum number, effluent releases may continue provided that prior to initiating a releases

a. Two independent samples are analyzed;

b. Two technically qualified members of the f acility staff verify the discharge line valving; i

,cherwise, suspend release of radioactive effluents via this pathway, i

(b) With the number operable of channels less than the required minimum number, effluent releases in this pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal gamma emitters at a limit of detection of at least 5x10-7 microcuries/ml. The principal gamma emitters for which the LLD specification applies exclusively are described in Note (c) to Table 2.2-1.

(c) With the number of operable channels less than the required minimum number, effluent releases via this pathway may continue provided the t flow rate is estimated at least once per four hours during actual releases. Pump curves or tank level decreases generated in situ aay be used to estimate flow.

3 e

[

i AmendmentNo.[ 5 t

I 8805260077 880519 PDR ADOCK 05000333 p DCD

_.--__.,___-_ . .~. . _ _ . _ _ _ _ - . _

TABLE 3.2-1 i

a. .

. RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit of Detection Minimunt G:seous Release Sampling Analysis Type of Activity (LLD)(a)

Type Frequency Frequency Analysis (uCi/ml)

-Main Stack and Monthly Monthly Principal Gamma 1 x 10-4 Rsfuel Floor Vent Grab Noble Emitters (D) and Sample (d) Gases (b)

R0 actor Building Vant and Quarterly Quarterly H-3 1 x 10-6 Turbine Building Grab Sample Vant and REdwaste Building Continuous (c) Weekly I-131 1 x 10-12 Vent Charcoal Sample (*) I-133 None l Continuous (c) Weekly Principal Gamma 1 x 10-11 Particulate Emitters (b)

S ample ( * ) (I-131, I-133, others) None l Continuous (C) 1 Wk/Mo Gross Alpha 1 x 10-11 Particulate S ample Continuous (c) 4 Wk/Qr Sr-89, Sr-90 1 x 10-11 Composite Particulate Sample Continuous (C) Noble Gas Noble Gases 1 x 10-5 Monitor Gross Beta or Gamma Incinerated Prior Each Principal Gamma 5 x 10-7 Oll(f) to Each Batch (9) Emitters (b) l

~

Batch (9) I-131 1 x 10-6 l Amendment No. p3 21 l

l l

l

. i HDIES FOR TABLE 3.2-1 (continusd)

(d) Main stack gaseous sampling and analysis shall also be performed following shutdown, startup, or a thermal power change exceeding 20% of rated thermal power in one hour.

1. This requirement app 31es only if o analysis shows that the dose equivalent I-131 concentration in the primary coolant has increased more than a factor of 3; and o The noble gas monitor shows that effluent activity has increased more than a factor of 3; and o Corrections for increases due to changes in thermal power level have been made in both cases.

(a) Main stack iodine and particulate sampling shall also be performed daily following each shutdown, startup or thermal power change exceeding 20% of rated thermal power in one hour.

1. Daily sampling is not required for thermal power changes if the off gas charcoal filters are in service.

2. In addition, this requirement applies only ift o Analysis shows that the dose equivalent I-131 concentration in the primary coolant has increased more than a factor of 3; and o The noble gas monitor shows that effluent activity has increased more than a factor of 3; and o Corrections for increases due to changes in thermal power level have been made in both cases.

3. Daily sampling shall be performed until two consecutive samples show no increase in concentration but not to exceed 7 consecutive days.

4. LLD s may be increased by a factor of 10 for analysis of daily samples.

5. Analysis of daily and weekly samples shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing.

(f) Incinerated oil may be discharged via points other than the main stack and l building vents (i.e., auxiliary boiler). Whenever oil samples cannot be filtered such as No. 6 bunker fuel oil, raw oil samples shall be collected and analyzed.

(g) Samples of incinerated oil releases shall be collected from and representative l of filtered oil in liquid form. Whenever oil samples cannot be filtered such as No. 6 bunker fuel oil, raw oils samples shall be collected and analyzed.

Amendment No.

23

, _ . - . . __ _ _ _ - . . . . _ = - _-

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS. *

'3.5 MAIN CONDENSER STEAM JET AIR EJECTOR (SJAE) 3.5 MAIN CONDENSER STEAM JET' AIR EJECTORS (SJAE)

Applicability Applicability Applies to n.aln condenser offgas discharge rate Applies to the point of discharge at the SJAE.

for noble gases.

t Obiective Obiective To ensure that the SJAE release rates are To ensure that the SJAE release rates 'are maintained at a level compatible for further properly monitored.

treatment and release.

Specifications Specifications  ;

a. The gross radioactivity (beta and/or gamma) a. The gross radioactivity . (beta and/or gamma) rate of noble gases measured at the SJAE is rate of noble gases from the SJAE shall be ,

given on Table 3.10-1. determined to be within the limits of Specification 3.5.a by performing an isotopic analysis of a representative sample of gases taken at the discharge (prior to dilution and/or, discharge) of the SJAE, or at the , recombiner discharge (prior to delay of the offgas to reduce the total ,

radioactivity) as follows:

1. At least monthly.

2. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ' following an increase as indicated by the SJAE Monitor, of greater than 50% (after factoring out increases due to _ changes in thermal power level) in the nominal steady state fission -gas release from the primary o

c'olant.

Amendment No.

28 7 .- -, - - -,c , , . , , . . . - , , ,y ~ ..- , 1- , - , - - , e , , , , , - . , ,

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

• 3.6 OFFGAS TREATMENT SYSTEM 3.6 OFFGAS TREATMENT SYSTEM Applicability Applicability Applies to the system installed for reduction of Applies to the calculation of the radiation dose radioactive materials in gaseous waste prior to from gaseous effluents containing radioactive discharge. materials.

Objective Objective To minimize concentration of radioactive To ensure that treatment of gaseous wastes by materials released from the site. the offgas system is implemented when required.

Specifications Specifications

a. The offgas treatment system shall be used to a. If the charcoal beds are not in service when reduce the concentration of radioactive the offgas treatment system is required, materials in gaseous efflucnts prior to doses due to gaseous releases from the site release from the plant within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after shall be projected at least monthly in the start-up of the second turbine driven accordz. ace with the ODCM.

feedwater pump.

Amendment No.

30

,m. ._

1. --

LIMITING CONDITIONS FOR OPERATION

^

SURVEILLANCE REQUIREMENTS .. 4

b. The offgas charcoal beds shall be used, when offgas treatment- ~ system operation is required and the projected doses over a 31 day period due to gaseous effluent releases to a member of the public would exceed:

I l

1. 0.2 mrad for gamma radiation

)

1

2. 0.4 mrad for beta radiation; or 1

3. 0.3 mrem to any organ

c. With gaseous effluent from the main I

condenser being , discharged without use of 1 the charcoal beds for greater than seven 4

days when treatment is' required, and projected doses are in excess of . the above limits, prepare and submit to the Commission, within 30-days, a Special Report I

that includes the following information:

f 1. Explanation of why gaseous . effluent is j being discharged without charcoal bed treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability,-

2. Action (s) taken to restore the a inoperable equipment to operable status; and i

j 3. Summary description of action (s) taken j to prevent a recurrence.

r Amendment No.

31

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS treatment system under the following condi- 1. An instrument check shall be performed tions: daily when the offgas treatment system is in operation.

1. The offgas dilution steam flow instrument- '

tation shall alarm and automatically 2. An instrument channel functional test l isolate the offgas recombiner system at shall be performed once per operating low flow less than 6000 pounds per hour cycle.

or high flow greater than 7200 pounds per hour. 3. An instrument channel calibration shall be performed once per operating cycle.

2. The offgas recombiner inlet temperature sensor shall alarm and automatically isolate the offgas recombiner system at a temperature of not less than 125'C.

l 3. The offgas recombiner outlet temperature shall alarm and automatically isolate the offgas treatment system at a temperature of not less than 150*C.

c. In lieu of continuous hydrogen or oxygen c. With condenser offgas treatment system monitoring, the condenser offgas treatment recombiner in .;e rvice, in lieu of continuous l

system recombiner effluent ; hall be analyzed hydrogen or oxygen monitoring, the hydrogen I l to verify that it contains less than or equal content shall be verified weekly to be less to 4% hydrogen by volume. than or equal to 4% by volume.

d. With the requirements of the above In the event that the hydrogen content cannot specifications not satisfied, restore the be verified, operation of this system may recombiner system to within operating continue for up to 14 days.

specifications or suspend use of the charcoal treatment system within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Amendment No. fI 33

TACLE 3010-1 . , ,

RADIATIOD MONITORING SYSTEMS THAT IDITIATE AND/OR ISOLATE SYSTEMS ,

Minimum No.

of Operable Total Number of Instrument Instrument Channels

_Chaupels Trio Function Trip Level Settino Provided by Desian Action l 1(a) Refuel Area Exhaust Monitor (b) 2 (c) or (d) l 1(a) Reactor Building Area Exhaust (b) 2 (d) l Monitors 1(a) SJAE Radiation Monitors 4500,000 pCi/sec 2 (e) 'l 1(a) Turbine Building Exhaust Monitors (b) 2 (f) l 1(a) Radwaste Building Exhaust Monitors (b) 2 (f) l 1(a) Main Control Room Ventilation {4 x 109 cpm (E) 1 (g) l (h) Mechanical Vacuum Pump Isolation f3 x Normal Full 4 (h) .'l Power Background NOTES FOR TABLE 3.10_1 (a) Whenever the systems are required to be operable, there s: ill be one operable or tripped instrument l channel per system. From and after the time it is found that this cannot be met, the indicated action a shall be taken.

(b) Trip level setting is in accordance with the methods and procedures of the CLCM (c) Cease operation of the refueling equipment.-

l (d) Isolate secondary containment and start the SBGTS.

(e) Bring the SJAE release rate within the limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot standby within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(f) Refer to Appendix B LCO 3.1.d.

(g) Control room isolation is manually initiated.

(h) Uses same sensors as primary containment isolation on high main steam line radiation. Refer to Appendix A Table 3.2-1 for minimum number of operable instrument channels and action required.

(i) Conversion factor is 8.15 x 107 cpm - 1 pC1/cc.

Amendment No. pI 37 I

t _. _ _ - _ _ _ - _ - .

I' . . ..

TABLE 3.10-2 ,

MINIMUM TEST AND CALIBRATION FREQUENCY FOR RADIATION MONITORING SYSTEMS (a)

Instrument Channel Logic System Instr Check gt Instrument Chan Functional Test Calibration Function Test 1Rstrument Channels Main Stack Exhaust Monitors Daily Quarterly Quarterly --

Refuel Area Exhaust Monitors Daily Quarterly Quarterly --

Reactor Building Area Exhaust Daily Quarterly Quarterly Sealannually Monitors / Isolation Turbine Building Exhaust Monitors Daily Quarterly Quarterly --

Radwaste Building Exhaust Monitors Daily Quarterly Quarterly --

SJAE Radiation Monitors /Offges Daily Quarterly Quarterly Semiannually Lin *=olation Main Control Room Ventilation Daily Quarterly Quarterly --

Monitor Mechanical Vacuum Pump Isolation 9 -- -- -- Once per Operating Cycle Daily When Quarterly Quarterly Semiannually Liquid Radwa g gj g { e Monitor /

Isolation Discharging

?

Daily Quarterly Once per Oper- --

LiquidRadwasteDiscpggeFlowRate ating Cycle Measuring Devices Daily Quarterly Once per Oper- --

LiquidRadwasteDisegggeRadio- ating Cycle activity Recorder Normal Service Water Effluent (f) Daily Quarterly Quarterly --

SBGTS Actuation -- --

-- Semiannually Amendment No. 93'

.['..-,'

NO*.*ES TO FIGURE 5.1-1 (a) NNP1 stack (height is 350 feet)

(b) NKP2 stack (height is 430 feet)

-(c) JAFbPP stack (height is 385 feet)

(d) Building vents (e) NNP1 radioactivo liquid discharge (Lake Ontario, bottom)

(f) NMP2 radioactive liquid discharge (Lake Ontario, bottom)

(g) JAFNPP radioactive liquid discharge (Lake Ontario, bottom)

(h) Site boundary ,

t (i) Lake Ontario shoreline

-Additional Information:

-- NNP2 reactor building vent is located 187 feet above ground level

-- JAFNPP reactor and turbine building vents are located 173 feet above ground level

-- JAFNPP radwaste building vent is 112 feet above ground level Amendment No. f5'

/. 9

TABLE 6.1-1 (continuid) ..

Exposure Sampling and Pathway Collection Type and Frequency and/or Sample Number of Samples (a) and Locations Frequency (a) of Analysis Fish a. 1 sample of each of 2 commercially or Twice per year. Gamma isotopic (C) recreationally important species in the analysis of edible vicinity of a site discharge point. portions.

b. 1 sample of each of 2 species (same as in a. above or of a species with similar feeding habits) from an area at least 5 miles distant from the site (d),

Food Products a. In lieu of the garden census as specified Once during Gamma isotopic (c) in 6.2, samples of at least 3 different harvest season. analysis of edible kinds of broad leaf vegetation (such as portions. (Isotopic vegetables) grown nearest each of two to include I-131.)

^

different offsite locations of highest predicted site average D/Q (Based on all licensed site Reactors).

One (1) sample of each of the similer broad leaf vegetation grown at least 9.3 miles distart in a least prevalent wind direction sector (d).

Amendment No. p 56

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liqTES FOR TABLE 6.1-1 l (a) The LLD is the smallest :oncentration of radioactive material in a

! sample that will be detected with 95% probability and with. 5%

, probability of falsely concluding that a blank observation represents a "real" signal.

l-For a particular measurement system (which may include radiochemical separation),

4.'66 sb LLD =

• V'

• E 2.22 Y* exp (- S t) l Where LLD is the a priori lower limit of detection, as defined above (in picocurie per unit mass or volume);

sb 's the standard deviation of the background counting rato or of the counting rate of a blank sample, as appropriate (in counts per minute);

i E is the counting efficiency (in counts per transformation);

V is the sample size (in units of mars or volume);

2.22 is the number of transformations per minute per picocurie; Y is the fractional radiochemical yield (when applicable);

A is the radioactive decay constant for the particular radionuclide; at is the elapsed time between sample collection (or end of the sample collection period) and time of counting.

l Typical values of E, V, Y, and At should be used in the calculations.

(b) It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement. Analyses shall be performed in such a inanner that the stated LLDs will be achieved under routine con-ditions. Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncon-trollable circumstances may render these LLDs unachievable. In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report.

(c) No drinking water pathway exists at the Nine Mile Point Site under normal operating conditions due to the direction and distance of the nearest drinking water intake. Therefore, an LLD value of 15 pC1/ liter is used.

Amendment No. jFI 60

. n .

7. The Radioactive Effluent Release Report shall contain the cause for unavailability of any environmental sample required by Table 6.1.1 and shall identify the locations for obtaining replacement samples. This shall also include a revised figure (s) and table for the ODCM reflecting the new location (c). Refer to Specification 6.1.c.

8. The Radioactive Effluent Release Report shall contain new locations identified in the land use census in accordance with Specifications 6.2.b or 6.2.c.

9. The Radioactive Effluent Release Report shall contain the events leading to the condition which resulted in exceeding 10 curies for tanks specified in the Limiting Conditions for Operation, Section 2.5.a.

d. Annual Radiological Environmental Operating Report Routine Radiological Environmental Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period.

The report shall include a comparison with preoperational studies, operational controls (as appropriata), and environmental surveillance reports from the previous five years, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of the Land Use Census required by Specification 6.2 The Annual Radiological Environmental Operating Reports shall include the results of analysis of all radiological environmental samples and of all measurements taken during the period pursuant to Table 6.1-1, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion in the report, the report chall note and explain the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following: A summary description of the Radiological Environmental Monitoring Program; at least two legible maps

• covering all sampling locations and keyed to a table giving distances and directions from the centerline of one reactor; the results of participation l in the Interlaboratory Comparison Program required by Specification 6.3 (or appropriate EPA cross-check program code), and discussion of all analyses in which the LLD's required by Table 6.1-3 were not routinely achievable.

• One map shall cover stations near the site boundary; a second shall include the more distant stations.

Amendment No. 73' 68

ATTACHMENT II TO JPN-88-021 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS APPENDIX A f

i i

i I

i I

NEW YORK POWER AUTIIORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT l DOCKET NO. 50-333 DPR-59 L

. C. Revisions of the ODCMt i

1. shall be submitted to the Commission in the Semiannual

. Radioactive Effluent Release Report for the period in which the revisions were made effective. This submittal shall contains

a. sufficiently detailed information to' support the rationale for the revisions without benefit of additional information (information submitted shall consist of revised pages of the ODCM, with each page numbered and provided with an approval and date box, together with appropriate evaluations justifying the revisions);

b. a determination that the revisions will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and

c. documentation that the revisions have been reviewed and found acceptable by the PORC.

j 2. shall become effective upon issue following review and acceptance by the PORC.

6.18 MAJOR MODIFICATIONS TO RADIOACTIVE LIOUID, GASEOUS AND SOLID i WASTE TREATMENT SYSTEMS

• A. Major modifications to radioactive waste systems (liquid, gaseous

, and solid):

1. shall be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the modification is completed and made operational. The discussion of each modification shall containt

a. a summary of the evaluation that led to the determination that the modification could be made in accordance with 10 CFR 50.59;

b. sufficient information to support the reason for the modification without benefit of additional or supplemental information; and

c. a description of the equipment, components and processes involved and the interfaces with other plant systems.

• The Authority may elect to submit the information called for in this Specification as part of the annual 10 CFR 50.59 Safety Evaluation Report.

Amendment No. ,93' 258c

ATTACHMENT III TO JPN-88-021 S AFETY EVALUATION FOR PROPOSED CHANGES RELATED TO RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS APPENDICES A & B NEW YORK POWER AUTIIORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59

e I 8e t Attachment III to JPN-88-021 SAFETY EVALUATION Page 1 of 11 Section I DESCRIPTION OF PROPOSED CRANGES This application for amendment proposes to revise certain portions of the FitzPatrick Radiological Effluent Technical Specifications (RETS), Appendix B, and Technical Specifications, Appendix A. These changes will further clarify and achieve consistency throughout RETS, and in no way change the intent of RETS.

Specifically, the following changes to RETS (Appendix B) are proposed:

[a] On page 5, Notes for Table 2.1-1, the current Note (b) defines the analysis required for gamma and beta emitters.

This method is changed arid the new Note (b) will read:

"With the number of operaL4e channels less than the required minimum, effluent releases in this pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal _9amma emitters at a limit of detection of at least 5 x 10 uCi/ml. The principal gamma emitters for which the LLD specification applies exclusively are described in Note (c) to Table 2.2-1."

[b] On page 21, Table 3.2-1, "Radioactive Gaseous Waste Sampling and Analysis Program," a new table entry for radioactive gaseous waste sampling and analysis "I-133" has been added.

j Type of Activity Analysis is "I-133"; and Lower Limit of Detection is "None."

[c] On page 23, Notes for Table 3.2-1, Note (d) has been reformatted for clarity as shown in Attachment I; Notes (e) and (f) have been combined and reformatted as shown in Attachment I; and the notes annotated (g) and (h) have been changed to read (f) and (g), respectively.

[d] On page 28, Section 3.5.a, a new condition for an isotopic analysis has been added (at the recombiner discharge) at the end of the first paragraph: " ..or at the recombiner discharge (prior to delay of the offgases to reduce the total radioactivity)."

The following changes are proposed for Specification 3.6, "Offgas Treatment System," on pages 30 and 31.

Attachment III to JPN-88-021 SAFETY EVALUATION Page 2 of 11

[e] Limiting Condition for Operation (LCO), Section 3.6.b, is deleted and replaced with a new Limiting condition for Operation (LCO) Specifications 3.6.b and 3.6.c, which contains requirements for charcoal beds to be in service when offgas treatment system operation is required.

(f) The surveillance requirement, Specification 3.6.a, is revised to correspond with the new LCOs.

The following changes are proposed for LCO Specification 3.7, "Offgas Treatment System Explosive Gas Mixture Instrumentation," on page 33.

[g] LCO Specifications 3.7.b.1, 3.7.b.2, and 3.7.b.3 have been changed to the following:

In Specifications 3.7.b.1, the word "primary" is deleted.

Also, the word "system" is added after offgas recombiner.

LCO Specifications 3.7.b.2 and 3.7.b.3 have been changed to the following:

2. The offgas recombiner inlet temperature sensor shall alarm and automatically isolate the offgag recombiner system at a temperature not less than 125 C.

3. The offgas recombiner outlet temperature shall alarm and automatically isolate the offgasg treatment system at a temperature of not less than 150 C."

[h] In Surveillance Requirement Specification 3.7.c, the following phrase has been added in the middle of the first sentence; " ..in lieu of continuous hydrogen or oxygen monitoring." In addition, the word effluent is added after recombiner in LCO specification 3.6.c for clarity.

The following changes are proposed for Table 3.10-1 "Radiation Monitoring Systems That Initiate and/or Isolate Systems" on page 37.

[i] Note (a) is removed from the "Minimum No. of Operable Instrument Channels" title and placed at each individual numbered instrument channels in that column.

[j] In the "Minimum No. of Operable Instrument Channels" column for the Mechanical Vacuum Pump Isolation, "2" has been deleted and replaced with note "(h)."

[k] The words "for Both Channels" have been deleted from the "Total number of Instrument Channels Provided by Design" column.

Attachment III to JPN-88-021 SAPBTY EVALUATION Page 3 of 11

[1] In Note (a), the phrase "..two operable or tripped instrument channels per trip system" is revised to read

..gne operable or tripped instrument channel per system."

[m] In Note (h), the second sentence will read:

"Refer to Appendix A, Table 3.2-1, for minimum number of operable instrument channels and action required."

The following changes are to Table 3.10-2, "Minimum Test and Calibration Frequency for Radiation Monitoring Systems," on page 38.

[n] Note "(i)" in the Instrument Channel Calibration title is deleted.

[o] The calibration entry for instrument channels "Turbine and radwaste building monitors" have been changed from "Semiannually" to "Quarterly."

(p] On page 49, Note (d) to Figure 5.1-1, the words "(ground level)*," and the corresponding (*) footnote stating that no credit taken for the elevations of these release points and therefore treated as ground level releases, is deleted.

[q) On page 56, Table 6.1-1 (Operational Radiological Environmental Monitoring Program) food product entries "a."

and "b'." are deleted. Also, entry item "c" is revised to read:

"a. In lieu of the garden census as specified in 6.2, samples of 3 of three different kinds of broad leaf vegetation (such as vegetables) grown nearest each of two different offsite locations of highest predicted site average D/Q (based on all licensed site reactors) .

One (1) sample of each of the similar broad leaf vegetationgrownatleastkaf.milesdistantinaleast prevalent direction sector "

[r] On page 58, Table 6.1-2, "Reporting Level For Radioactivity Concentrations In Environmental Samples", the reporting level entry for water has been changed from "2" to "20" for Iodine-131.

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Attachment III to JPN-88-021 SAFETY EVALUATION Page 4 of 11

[s] On page 59, Table 6.1-3, "Detection capabilities For Environmental Sample Analysis Lower Limit Of Detection", the detection capability entry for water has been changed from

"'" to "15" for Iodine-131.

[t] On page 60, Notas for Table 6.1-3, Note (c) is revised to read:

"(c) No drinking water pathway exists at the Nine Mile Point Site under normal operating conditions due to the directions and distance of the nearest drinking water intake. Therefore, an LLD value of 15 pCi/ liter is used."

[u] On page 68, Specification 7.3.d (Annual Radiological Environmental Operating Report), delete the word "the" from the fourth paragraph ("centerline of the reactor") and revise the phrase to read "centerline of one reactor."

The following change is proposed for the Technical Specifications (Appendix A):

(v) On page 258c, Specification 6 18 "Major Modif1:ations To Radioactive Liquid, Gaseous And Solid Waste Treatment Systems," the asterisk footnote, which provides an alternative to submit the information in this Tech Specs as part of the FSAR update, is changed to provide the l information called for as part of the 10 CFR 50.59 annual report.

Section II PURPOSE OF THE PB_OPOSED CHANGES On July 1, 1985 the NRC issued RETS for FitzPatrick as Amendment 93 to the Operating License. Since the issuance of RETS, m.nor problems or errors that require clarification or correction have arisen. The proposed changes clarify or correct these minor items and in no way change the intent of RETS. The l prop;;:S changes are designed to improve and facilitate the use j of RETS.

The proposed change (item (a)) to Note (b) for Table 2.2-1 redefines the method for analysis of gamma emitters. The current specification requires a "gross radioactivity (beta or gamma)"

analysis if monitors do not meet operability requirements.

However, a principal gamma emitter analysis l

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O Attachment III to JPN-88-021 SAFETY EVALUATION Page 5 of 11 would be more appropriate. This is because gamma emitters are analyzed by gamma spectroscopy that is reliable, readily available, and more accurate than gross gamma analysis.

The proposed change (item (b)) to Table 3.2-1, "Radioactive Gaseous Waste Sampling and Analysis Program," on page 21, adds Iodine-133 for activity analysis (dose determination) . This change is consistent with Section 3.2 for gaseous dose rates and FitzPatrick's Offsite Dose Calculation Manual (ODCM). A method for the dose determination of Iodine-133 is included in the ODCM.

This change will clarify Table 3.2-1 for consistency.

The proposed changes (item (c)) to page 23 will clarify the notes. The intent of the notes, however, is not changed. The footnotes in Table 3.2-1, on page 21, are changed to correspond with the new footnotes.

The proposed change (item (d)) to Surveillance Requirement 3.5.a, on page 28, clarifies the noble gas sample location stated in this specification. Currently, the sampling location is at the discharge of the SJAE. This is too restrictive and non-conservative. During offgas recombiner operation, the most representative sample of gross radioactivity release rate of noble gases from the main condenser is obtained at the recombiner discharge. Therefore, sampling of offgas should also be allowed at the recombiner discharge.

The preposed changes (items (e) & [f]) to the "Offgas Treatment System," Specification 3.6, adds new LCOs and the corresponding surveillance requirement. The new Specifications (3.6.b and 3.6.c) address the charcoal bed bypass capability and clarifies specification 3.6.

The Offgas Treatment System at the FitzPatrick plant includes the capability to bypass the charcoal beds. This l bypass capability should be addressed in RETS. Specifically, the I

expected dose from gaseous effluent releases to a member of the public should be projected when the charcoal beds are bypassed.

The dose impact from the one month release should be compared to l 0.2 mrad for gamma radiation, 0.4 mrad for beta radiation, or 0.3 l mrem to any organ. If the dose projection indicates that these

values will be exceeded, then the charcoal beds must be used.

The values for the projected impact correspond to approximately one forty-eighth of the annual design dose objective values of 10 CFR 50 Appendix I, in one month. If continued for one l year, these values would correspond to less than one-fourth the l corresponding annual limits.

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o Attachment III to JPN-88-021 SAFETY EVALUATION Page 6 of 11 Calculations for projected cumulative doses that could result from bypassing the charcoal beds will be performed according to the method provided in FitzPatrick's ODCM. This proposed change requires the use of the offgas treatment system during power operation or notification of the NRC.

The proposed changes (item [g]) to LCO Specifications 3.7.b.2 and 3.7.b.3 clarify two of the three conditions that govern the automatic isolation of the offgas treatment system.

These two conditions deal primarily with the offgas recombiner inlet and outlet temperature sensor instrumentation limits. The current specifications are confusing, since the offgas recombiner is not properly described.

Surveillance Requirement 3.7.c verifies that offgas treatment system discharge hydrogen concentration be less than 4%

by volume, weekly. This is 'ntended to accompany the associated LCO requirement 3.7.c, which requires verification of the amount of hydrogen in the system. fhe proposed change (item [h]) will clarify this surveillance requirement.

The proposed changes (items [i] thru [m]) to Table 3.10-1 clarify the notation for footnote (a). Footnote (a) only applies to the first six trip functions listed in that table not including the Mechanical Vacuum Pump Isolation Trip Function. In addition, Note (a) is clarified to state that there shall be one operable or tripped instrument channel per system, since only one trip channel is required for operation. The words "for Both Channels" are deleted from the heading of the table for clarity.

The proposed changes (items (n) and [o]) to Table 3.10-2 delete note (i) from the calibration column, since it only applies to instrument channel functional testing. This was a typographical error. Also, the instrument channel calibration i frequency, for the turbine and radwaste building exhaust, has l been changed from "semiannually" to "quarterly" for consistency.

This is in keeping with current procedures for channel calibration frequency.

The proposed change (item {p]) to Note (d) for Figure 5.1-1 (Site Boundary Map), on page 49, deletes the words "ground level *," with the corresponding footnote. The footnote (*)

erroneously states, "No credit taken for the elevations of these release points and therefore treated as ground level releases."

The release points from the building vents are commonly called ground level as opposed to stack releases which are called elevated. However, offsite dose calculations do i

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Attachment III to JPN-88-021 SAFETY EVALUATION Page 7 of 11 take into account the actual elevation of the vents. The procedure for calculating offsite doses is in the ODCM.

The proposed changes (item [q)) to Table 6.1-1, "Operational Radiological Environmental Monitoring Program," on page 56, are consistent with Nile Mile Point Units 1 & 2 RETS. The contents found under the subheading Food Products (items a. and b.) are deleted, since it provides an alternative for milk sampling.

Milk sampling has been performed since 1974 and will be continued in the future. This program is a site program that includes NMP Units 1 & 2 and FitzPatrick. These changes also meet NRC criteria found in the Standard Technical Specification for boiling water reactors.

The proposed changes (items [r), [s], & [t]) to Tables 6.1-2

& 6.1-3, on pages 58, 59, & 60, delete the reporting levels of 1 and 2 pCi/ liter for Iodine-131 in water samples. Due to the direction and distance of the nearest water intake, the Nine Mile Point site (NMP), which includes the FitzPatrick plant, does not have a drinking water pathway under normal operating conditions. To be consistent with the most recent NRC criteria and NMP site RETS, values of 15 and 20 pCi/ liter for Iodine-131, in water samples, are used. Also, the corresponding footnote (c), on page 60, is revised to be consistent with the changes made in Table 6.1-3 for drinking water samples.

The proposed change (item [u]) to specification 7.3.d, on page 68, clarifies the reactor centerline appointed for the environmental sample locations listed in the Annual Environmental Operating Report. The words "the reactor" are replaced with "one reactor" to allow the use of either the Nine Mile Point Unit 2 or FitzPatrick reactor centerline.

Previously, the distances and directions of environmental sample locations have been calculated using the NMP Unit 2 reactor centerline. The NRC guidance allows the use of center of reactors for sites with joint environmental programs for the calculation of distance and direction of environmental sample locations. The FitzPatrick plant will continue to use the Nine Mile Point Unit 2 reactor centerline in Annual Environmental Operating Reports.

Lastly, the proposed change (item [v]) to the Technical Specifications (Appendix A), eliminates the FSAR as an alternative for reporting modifications to the radioactive waste system. This requirement will be furnished in either the semiannual report or the annual 10 CFR 50.59 Safety Evaluation Report.

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Attachment III to JPN-88-021 SAFETY EVALUATION Page 8 of 11 Section III IMPACT OF THE PROPOSED CRANGER The proposed changes to the RETS, Appendix B, and Technical Specifications, Appendix A, will not impact plant safety or operation. All of the changes are administrative or editorial in nature. There are no setpoint changes regarding isolation or alarms. The proposed changes do not involve safety limit changes. These changes clarify or correct errors as currently written in the specifications. The proposed changes are designed to improve and facilitate the use of RETS. These changes will help the plant operators by achieving consistency and reducing the necessity for interpretation of RETS.

The proposed change, on page 5, to the current Note (b),

does not impact plant operations, since it clarifies grab sample analysis for radionuclides.

The proposed change related to additional specification and reporting requirements, Specification 3.6, does not impact plant operation, since it clarifies the charcoal beds operability when bypassed. Projected cumulative doses that could result from bypassing the charcoal beds, will now be monitored.

The addition of Iodine-133 proposed to Table 3.2-1 on page 21, and the rearrangement of the table footnotes on page 23, are needed to achieve consistency throughout RETS. These proposed changes, therefore, are administrative in nature and do not impact facility operation.

The proposed change related to the sampling location for gross radioactivity release rate of noble gases, Surveillance Requirement 3.5.a, provides an alternative location for better sampling. The current specification is too restrictive when sampling during different modes of offgas recombiner operations.

This change will not affect plant operations.

The proposed changes to pages 56, 58, 59, 60, and 68 do not impact facility operation. They are administrative in nature and consistent with the Nile Mile Point RETS.

The proposed change in Appendix A, on page 258c, eliminates the FSAR as an alternative for reporting major modifications to radioactive waste systems. This change does not impact facility operation, since the reporting requirements will be included in either the semiannual radioactive effluent release report or the annual 10 CFR 50.59 safety evaluation report.

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Attachment III to JPN-88-021 SAFETY EVALUATION Page 9 of 11 The proposed changes to RETS, Appendix B, and the Technical Specifications, Appendix A, do not change any system or subsystem and will not alter the conclusions of either the FSAR or SER accident analysis.

Section IV EVALUATION OF SIGNIFICANT HAZARDOUS CONSIDERATIONS The proposed changes to the James A. FitzPatrick RETS, Appendix B, and Technical Specifications, Appendix A, involve no significant hazard considerations. They are administrative changes such as: correction of an error; a change in nomenclature; or clarification of a specification. Operation of the FitzPatrick plant in accordance with the proposed amendment would not involve significant hazards considerations as defined in 10 CFR 50.92, since it would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated, because the changes are only designed to clarify and correct RETS.

They are administrative changes such as: consolidating footnotes; clarifying wording; and correcting reporting levels to achieve consistency with Nile Mile Point. There is no impact on plant operations. There are no setpoint changes regarding isolation or alarms. There is no change to the environmental monitoring program. The changes wi.'1 have no impact on previously evaluated accidents.

(2) create the possibility of a new or different kind of accident previously evaluated. As stated above, the proposed amendment does not involve physical changes to the facility. The changes are administrative in nature and do not involve safety limit changes. These proposed changes are intended to further clarify and improve RETS.

The changes cannot create a new or different accident.

(3) involve a significant reduction in the margin of safety.

The nroposed amendment will achieve consistency throughout the specifications and clarify or correct errors. There is no impact on plant operations, nor are there any setpoint or safety limit changes regarding isolation or alarms. There is no change to the environmental monitoring program. The proposed changes are designed to improve and facilitate the use of RETS. The changes will assist the operator in better understanding of these specifications. The proposed changes do not reduce safety margins of any kind.

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! Page 10 of 11 The Authority considers that the proposed changes can be classified as not likely to involve significant hazards considerations, since the changes are administrative in nature and do not invo.lve hardware changes nor any changes to the plant's safety related structures, systems, or components.

The proposed changes are designed to improve and facilitate the use of RETS.

Section V IMPLEMENTATION OF THE PROPOSED CRANGE8 Implementation of these changes, as proposed, will not impact the ALARA, Security, or Fire Protection Programs at FitzPatrick, nor will the changes impact the environment.

Section VI CONCLUSION The proposed changes do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

a. will not change the probability or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report;

b. will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report;

c. will not reduce the margin of safety as defined in the basis for any technical specification;

d. do not constitute an unreviewed safety question; and

e. involve no significant hazards consideration, as defined in 10 CFR 50.92.

Section VII REFERENCES

1. James A FitzPatrick Nuclear Power Plant Final Safety Analysis Report (FSAR).

2. Janas A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER).

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3. PASNY letter, L. Sinclair to D. Vassallo, dated April 29, 1983.

4. NYPA letter, C. McNeill, Jr. to D. Vassallo, dated December 21, 1984 (JPN-84-086) regarding RETS Amendment Application.

5. NRC letter, H. Abelson to C. McNeill, dated July 1, 1985 ([[::JAF-85-202|JAF-85-202]]) regarding the issuance of RETS.

6. U. S. Nuclear Regulatory Commission, Rules and Regulations, Title 10, Code of Federal Regulations Part 50, Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet 'As Low As Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents".

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7. USNRC NUREG-0473, Standard Radiological Effluent Technical Specifications for Boiling Water Reactors, Rev. 3.

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