ML20196C469

Proposed Tech Specs Incorporating Revised Surveillance Requirement for Gaseous Waste Releases

ML20196C469
Person / Time
Site:	Fort Calhoun
Issue date:	02/08/1988
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20196C460	List: ML20196C458 ML20196C462 ML20196C469
References
NUDOCS 8802160110
Download: ML20196C469 (9)

Text

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2.0 -LIMITING CONDITIONS FOR OPERATIONS ' fNMy~

2.9 R .dioretivo Efflutnts //

2.9 1 Liquid and Cassou, Efflutnts h fp [/)g Applicability _  !

Applies to the controlled release of radioactive materials in liquid and gaseous effluents from the facility. The provisions of Technical Speci-fication 2.0.1 for Limiting Condition for Operation are not applicable.

Objective To define the limits and conditions for the controlled release of radio-active materials in liquid and gaseous effluents to the environs to ensure

. that these releases are as lov as is reasonably achievable in conformance with 10 in result CFR Tofeed

.g Pag $_ _t_ = gag 0.36a, and to ensure that these releases m

radioactivegterials in liquid and gaseous effluents released to unrestricted areasvare within the limits specified in 10 CFR Part 20.

To ensure that the releases of radioactive materials above background to unrestTicted areas are as lov as is reasonably achievable, the following r -

design objectives apply.

A. Liquid Effluents (1) The dose or dose commitment to a member of the public during any calendar year should not exceed _3. millirems to the total body.

(2) The dose or dose commitment to a member of the public during any calendar year should not exceed _1,0, 0 millirems to any organ. _l B. Gaseous Effluents ,

I (1) The calculated annual air dose due to gamma radiation at any location which could be occupied by individuals in unrestricted sreas should not exceed 10 millirads; i (2) The calculated annual air dose due to beta radiation at any location which could be occupied by individv0.s in unrestricted ,

areas should not exceed' 20 millirads ; and ,

( 3) The calculated annual total quantity of iodine-131, tritium, l and all radioactive material in _ particulate form with half-  :

lives greater than 8 days should not result in en annual dose i or dose commitment to any organ of an individual in an  ;

unrestricted area from all pathways of exposure in excess of 15 millire s.

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2-h0 AmendmentDo.//

g2160110880208' '

p ADOCK O5000295 PDR

s 2.0 LIMITING CONDITIONS FOR OPEFATION 2.9 Radioactive Effluents (Continued) 291 Liouid and Gaseous Effluents (Continued)

(1) Specifications for Liauid Waste Effluents

a. (1) The release rate of radioactive material in liquid eft:xents shall be controlled such that the instan-taneous concentrations for radionuclides, other than dissolved or entrainea noble gases, do not exceed the values specified in 10 CFR Part 20 Appendix 3, for  !

unrestricted areas. Far dissolved or entrained noble gases , the concentration shall be limited to 2.0 E-Oh

,g m W i/ml total activity.

(ii) With the concentration of radioactive material released to unrestricted areas exceeding the above limits, appropriate corrective actions shall be taken immediately to restore concentrations within the above limits,

b. The cumulative dose contributions from radioactive materials in liquid effluents released to unrestricted areas shall be deter-mined, in accordance with the CDCM, on a quarter'ly basis. If the doce contributions, due to the cwnulative release of liquid effluents averaged over a calendar quarter, exceed one-half of the design objectives, the following course of actions shall be taken:

(i) Make an investigation to identify the causes for such releases.

(ii) Define and initiate a program of action to reduce such releases to the design levels.

(iii) Submit a special report, pursuant to Specification 5.9 3, within 30 days from the end of the quarter during which release occurred, identiff ing the causes and describing the proposed progra= of action to reduce such release to the design levels,

c. The equipment or subsystem (s) of the liquid radvaste treatment system as identified in the ODCM shall be operated prior to the discharge of radioactive materials in liquid vastes. If the radioactive liquid vastes were discharged without treatment by one or more of the pieces of equipment or subsystem (s) identified in the ODCM and it appears that one-half of the annual objective vill be exceeded during the calendar quarter, a special report, pursuant to Specification 5.9.3, shall be prepared and -ubmitted to the Commission within 30 days. This report shall include the following information:

(i) Identification of equipment or subsystems not operable and reason for inoperability.

2 kl Amendment No. 23,/$ ,

2.0 LIMITING CONDITIONS MR OPERATIONS 2.9 Radioactive Effluents (Continued) ,

291 Liquid and Gaseous Effluents (Continued) operable radiation monitor. If both radiation monitors are inoperable, steam generator liquid release may continue provided appropriate grab samples are analyzed for principal gamma emitters at a sensitivity of 5 0E-07 pCi/ml and recorded at least daily when the specific activity of the sample is less than or equal to 0.01 pCi/ gram dose equivalent I-131 and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is grester than 0.01 pCi/ gram dose equivalent I-131. If the radioactivity cannot be recorded automatically, effluent releases may continue provided the gross radioactivity level is recorded manually at least once per four hours during actual release.

(2) Soecifications for Gaseous Waste Effluents

a. (i) The release rate of radioactive materials in gaseous effluents shall be controlled such that the f ~ tan-hm concentrations of radionuclides do not exceed the values specified in 10 CFR Part 20, Appendix B, val /< 2j for unrestricted areas univ &chc/ onca conugtnd/cor chaH (ii) bsWith calculakd bacu/ on of& radioactive the concentration annual avmyc g, re material leased to unrestricted areas exceeding the above limits , appro-priate corrective actions shall be taken immediately to restore concentration within the above limits.

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b. The -cu=lative dose contributions to each of the 16 a di.iG

-sectore, from radioactive materials in gaseous effluents shall be determined, in accordance with the ODCM, on a quarterly basis ~.

If the dose contributions , due to the cumulative release of gaseous effluents averaged over a calendar quarter exceed one-half of the design objectives , the folleving course of actions shall be taken:

(i) Make an investigation to identify the cause for such release rates.

(ii) Define and initiate a program of action to reduce such releases to design levels.

(iii) Submit a special report, pursuant to Specification 5.9.3, within 30 days from the end of the quarter during which release occurred, identifying the causes and describing the proposed progran of action to reduce dose cos.,ribu-tions.

c. The equipment or subsystem (s) of the gaseous r" taste treatment system as identified in the ODCM shall be operced prior to the discharge of radioactive materials in gaseous vastes. If the radioactive gaseous vastes were discharged without treatment by i

2 L3 Amendment No.

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200 LIMITING C04DITIONS FOR OPERATIONS 2.9 Radioactive Effluents (Continued) 2.9 1 Liquid and Baseous Effluents (Continued)

Basis (Continued)

Specification 2.9.l(l)d, consistent with the requirements of General Design Criteria 60 and 64 of 10 CFR Part 50, Appendix A, requires operation of suitable equipment to dilute, control, and monitor the releases of radio-active materials in liquid vastes , other than steam generator liquid, from the overboard header during any period when releases are taking place.

Specification 2 9.1(1)e requires the monitoring of the steam generator liquid when releases are being discharged to the environment. Inoperabil-ity of one radiation monitor vill not affect the monitoring capabilities as the other radiation monitor vould serve the intended purpose. If both radiation monitors are found inoperable and if steam generator liquid is being released to the environment, the specified sampling frequency pro-vides assurance that no major activity is released during a limited period l of time when repairs are being made.

The release of radioactive materials in gaspous vaste effluents to unre-stricted areas vill not result in"Ec$EEEtr5.ibfe that exceed limits specified in 10 CFR Part 20 at any time and should be as low as is reason-ably achievable in accordance with the requirements of 10 CFR Parts 50.34a and 50.36a. These specifications provide reasonable assurance that the resulting annual air dose due to gamma radiation vill not exceed 10 mrad and that the resulting annual air dose to beta radiation vill not exceed 20 mrad from the gaseous vaste effluents from the plant. These specifica-tions also provide reasonable assurance that no individual in an unrestrict ed area vill receive an annual dose to the total body greater than 5 mrem or on annual dose to the skin greater than 15 mrem from these gaseous effluents ,

and that the annual dose to any organ of an individual from radiciodines and radioactive material in particulate form vill not exceed 15 mrem.

At the same time, these specifications permit the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided with a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such numerical guides for design objectives but still within levels that assure that the average population exposure is equivalent to small fractions of doses from natural background radiation.

onnualetecc of Specification 2.9.1(2)a requires . the licensee to limit the -cence"+retien radioactive materials in gaseous effluents from the station to levels speci -

fied in 10 CFR Part 20, Appendix B, for unrestricted areas. This specifica-tion provides assurance that no member of the general public vill be exposed at any time to gases containing radioactive materials in excess of limits specified in the Co= mission's regulations.

Specification 2.9.1(2)b establishes the frequency of dose calculations in accordance with the ODCM. This specification also establishes the reportina 2 L6 AmendmentNo.12,/hI '

r 5.9.3 Special Reports Special reports shall be submitted to the Regional Administrator of the appropriate NRC Regional Office within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification where appropriate:

a. In-service inspection report, reference 3.3.

b. Tendon surveillance, reference 3.5.

c. Containment structural tests, reference 3.5.

d. Special maintenance reports.

e. Containment, leak rate tests, reference 3.5.

f. Radioactive effluent releases, reference 2.9.

g. Materials radiation surveillance specimens reports, reference 3.3.

h. Fuel perfonnance following each refueling outage. ,

i. Fire protection equipment outage, reference 2.19.

j. Post-accident monitoring instrumentation, reference 2.21. l 5.9.4 Unique Reporting Requirements

a. Radioactive Effluent Release Report A report covering the operation of the Fort Calhoun Station during the previous six months shall be submitted within 60 days after January 1 and July 1 of each yearper tA. regoirmais10450.3 ceg, Get The radioactive effluent release report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant.n cutlin:d '- Reguhtery- .

%'t 1. L lavision L The radioactive effluent release report shall include a sumary of l the meteorological conditions concurrent with the release of l gaseous effluents during each quarter.as cutl%:d in Regulatory l

Ouide 1.21, Revisie -1r m.

The radioactive effluent release report shall include an assessment of radiation doses from the radioactive liquid and gaseous effluents j released from the unit during each calendar quarter.es-eet44ned-4e l bguiet;ry Cuide 1.21, Revister ' - In addition, the unrestricted area boundary maximum noble gas gama air and beta air doses shall be evaluated. The meteorological conditions concurrent with the 5-15 Amendment No. 9,24,38,46,8d'///

n Attachment B Justification and Significant Hazards Considerations This proposed change to Appendix A of Operating License DPR 40 will clarify the current specifications to ensure compliance with 10 CFR Parts 20.105 and 20.106, 10 CFR Part 20 Appendix B, 10 CFR Part 50.36a and 10 CFR Part 50 Appendix I.

This clarification will permit the use of annual average relative concentrations (x/Q and D/Q for dispersion and deposition, respectively).

These annual average x/Q and D/Q values will be used for determination of gaseous effluent release rates and radiation doses in the unrestricted area resulting from those effluents. This concept is consistent with NUREG 0472 (Draft 7 of Revision 3 dated September 1982), "Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors," and endorsed by NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for i Nuclear Power Plants," dated October 1978.

The concept of gaseous effluent release rate and resultant unrestricted area radiation dose determinations using annual average x/Q and D/Q values is endorsed by the NRC based upon issuance of Amendments 105 and 86 to Facility Operating License Numbers DPR-53 and DPR 69 for Calvert Cliffs Nuclear Power Plant Units 1 and 2, respectively. Support for issuance of the license amend-ments referenced above is Technical Evaluation Report TER C5506 87/88, dated November 30, 1984, prepared by the Franklin Research Center. Further endorse-

, ment of this concept is provided by the Commission's issuance of Amendment 64 to Facility Operating License No. DPR 43 for the Kevaunee Nuclear Plant and sup-ported by Idaho National Engineering Laboratory Report EGG-PBS 6883, dated July 22, 1985. All three amendments and supporting Offsite Dose Calculation Manuals (ODCM) utilize the concept of annual average x/Q and D/Q values for release rate and radiation dose determination.

The specific changes to the Fort Calhoun Station Technical Specifications are described below. The objective of Section 2.9.1 is changed to relate the cri-teria for regulatory compliance to annual radiation doses from effluents rather than to radionuclide concentrations in the effluents.

Paragraph 2.9.1(1)a(i) is changed to correct a typographical error in the units for the concentration of dissolved or entrained noble gases in liquid effluents.

The change is from millicuries / milliliter to microcuries/ milliliter.

Paragraph 2.9.1(2)a(i) is changed to delete the word "instantaneous" in refer-ence to radionuclide concentrations and to use the annual average x/Q value for determination of nuclide concentrations. Effluent release rates will con-i tinue to be controlled such that radionuclide concentrations will be in compli-ance with 10 CFR Part 20 Appendix B in accordance with 10 CFR Part 20.106(a),

i The program for control of effluent release rates based upon radionuclide con-centration and atmospheric dispersion factors (x/Q values) is established and works well.

In Paragraph 2.9.1(2)b the word "cumulative" is changed to "radiation" and the words "to each of the 16 cardinal sectors" are deleted in reference to quarterly f calculations to ensure compliance with the annual dose design objectives of l

Paragraph 2.9.1.B. The radiation doses resulting from gaseous effluents will i

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continue to be calculated on a quarterly basis and compared to 50% of the de-sign objectives. However, the calculation will' assume all effluents during a given calendar quarter are dispersed in the most limiting. sector in the South-Southeast direction on the basis of the highest calculated annual average

.x/Q value. This assumption is conservative and will ensure compliance with the design objectives. These calculations will be performed in accordance with the Fort Calhoun Station ODCM.

The Basis for Section 2.9.1 is changed to replace the word "concentration" with the words "annual dose" for consistency with the specifications of the section.

. Paragraph 5.9.5.a is changed to add a reference to 10 CFR Part 50.36a for the semi-annual reporting of radioactive effluents and deletes reference to Regula-tory Guide 1.21, Revision 1, for the reporting format. Deletion of_the Regula-tory Guide 1.21, Revision 1. reference for the effluent release report format will provide flexibility in reporting of the results from the quarterly dose calculations to ensure compliance with the design objectives in Paragraphs 2.9.1.A and 2.9.1.B. The Omaha Public Power District will continue to report the effluent release summaries and meteorological information required under_10 CFR 50.36a in the format prescribed in Regulatory Guide 1.21, Revision 1, until guidance on reporting format is updated.

As previously noted, the changes proposed herein are consistent with NUREG-0472, Draft 7 of Revision 3 and NUREG 0133. The primary motivation for these proposed changes to the Technical Specifications in Section 2.9.1 is OPPD's desire to minimize personnel radiation exposures during entry to the Contain-ment Building in the initial stage of Fort Calhoun Station refueling outages.

This is consistent with the ALARA concept related to worker radiation exposure and OPPD's ALARA program.

Implementation of gaseous effluent release rate control based upon annual aver-age atmospheric conditions (annual average x/Q) will allow faster purging of the Containment Building while not jeopardizing the health and welfare of the general public. Compliance with the limits provided in 10 CFR Part 20.105, Part 20, Appendix B, and 10 CFR Part 50, Appendix I, and the ALARA concepts of 10 CFR Part 50.36a will be maintained.

Historically, the radiation doses and radionuclide concentrations in the unre-stricted area resulting from gaseous and liquid radioactive effluents from the Fort Calhoun Station have been small fractions of the limits prescribed in 10 CFR Part 20 and Appendix I to 10 CFR Part 50. Utilization of the annual aver-age x/Q for control of gaseous effluent release rates is not expected to increase the radionuclide concentrations and their associated radiation doses above current levels. This expectation is based upon the concept that the annual cumulative result of high release rates during atmospheric conditions conducive to effluent dispersion and low release rates during atmospheric con-ditions not conducive to effluent dispersion is the same as a single release rate controlled by annual average atmospheric conditions.

S Sicnificant Hazards Considerations The proposed changes do not involve significant hazards based on the following information.

Will the change involve a significant increase in the probability or conse-quences of an accident previously evaluated?

No. The subject changes do not involve a material alteration of equipment or a change in the method of monitoring routine radioactive gas releases. The pro-posed changes do not alter any inputs or methedologies utilized in safety anal-yses for the Fort Calhoun Station. The change in the requirements for report format has no impact on plant safety.

Will the change create the possibility of a new or different kind of accident from any accident previously evaluated?

No. The change involves no alteration of equipment, no change in gaseous re-lease quantities and no change in release pathway. The change will simplify the gas releases for the operations staff and, therefore, reduce the possibil-ity of human error. The proposed changes do not alter any inputs or methodol-ogies utilized in safety analyses for the Fort Calhoun Station. The change in the requirements for report format has no impact on plant safety.

Will the change involve a significant reduction in a margin of safety?

No. The annual exposure to a member of the public will not increase because the quantity of gas released annually will not increase. The proposed changes are expected to reduce the overall uncertainty in regulating radioactive gases dur-ing routine releases to unrestricted areas. The submittal meets the intent of NUREG 0472 for annual doses from gaseous effluents. The annual dose limits are the doses associated with the concentrations of 10 CFR 20, Appendix B, Table II, Column 1. These limits provide reasonable assurance that radioactive mater-ial discharged in gaseous effluents will not result in the exposure of a member of the public in an unrestricted area outside the site boundary to annual aver-age concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR 20. The specified release rate limits in accordance with NUREG 0472, re-strict the corresponding gamma and beta dose rates above background to a member of the public at or beyond the site boundary, to less than or equal to 500 mrem / year to the total body and less than or equal to 3,000 mrem to the skin.

These release rate limits also restrict the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem / year. The 10 CFR 50 annual exposure objectives are more restrictive than the 10 CFR 20 annual dose rates. The Fort Calhoun Station has never ex-ceeded the more restrictive 10 CFR 50 annual exposure objectives. Quarterly calculations will be done to track the status of the 10 CFR 50 annual exposure objectives as per the Technical Specification 2 9.2B (1), (2), and (3).

If the quarterly dose calculational results exceed one half the design objec-tives, an investigation will be done, action will be taken to reduce the doses to the objectives and a special report will be submitted to the Commission in accordance with Technical Specification 2.9.l(2)b. The proposed changes do not alter any inputs or methodologies utilized in safety analyses for the Fort Cal-houn Station.

The proposed deletion of Regulatory Guide 1.21, Revision 1, from the Technical Specification and the addition of 10 CFR 50.36a does not involve a reduction in

a the margin of safety. -The deletion of. the Reg. Guide commitment will allow the report to reflect a comprehensive assessment of compliance to the Radiological Environmental Technical Speciffcations.

For the stated reasons, Omaha Public Power District does not believe the pro-posed changes to the Technical Specifications involve any significant hazards, i

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