ML20206J556

Discusses Inconsistency Between Tech Spec 3.17.3 & Surveillance Requirement of Tech Spec 4.21.3,per Insp Findings from Insp Rept 50-312/86-15.Requests Advisement If Curie Content Limit Required to Be Applied to All Tanks

ML20206J556
Person / Time
Site:	Rancho Seco
Issue date:	06/23/1986
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Miraglia F Office of Nuclear Reactor Regulation
References
TAC-61908, NUDOCS 8606270196
Download: ML20206J556 (4)

See also: IR 05000312/1986015

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MEMORANDUM FOR: ' FEank J.'Maragila,'Jr., Director, Division of PWR

. Licensing "B", NRR

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FROM: Ross A. Scarano, Director, Division of Radiation Safety

and Safeguards, Region V

SUBJECT: REQUEST FOR TECHNICAL ASSISTANCE, RANCHO SECO, DOCKET NO.

50-312, CURIE LIMITS IN OUTSIDE STORAGE TANKS

In response to recent inspection findings as documented in Inspection Report

No. 50-312/86-15, an issue has developed which we request that you resolve.

The licensee's Technical Specification 3.17.3 seems to require that the 10

curie content limit be applied only to the Regenerant Holdup Tanks and outside

temporary tanks. The licensee has implemented their surveillance requirement

(Technical Specification 4.21.3) to only these tanks.

An asterisked remark in Technical Specification 4.21.3 states:

" Tanks included in this specification are those outdoor tanks that are

not surrounded by liners, dikes, or walls. capable of holding the tank

contents and that do not have tank overflows and surrounding area drains

connected to the liquid radwaste treatment system."

Several tanks such as the Borated Water Storage, Demineralized Reactor Coolant

Storage, and Miscellaneous Water Holdup Tank are located outdoors and are not

surrounded by liners, dikes, or walls capable of holding the tank contents.

The Rancho Seco FSAR does not seem to address the impact of these tank

failures on surface waters as discussed in Revision 3 of NUREG-0472.

Technical Specification 3.17.3 does not appear to be consistent with the

surveillance requirement of 4.21.3.

Please advise Region V if a curie content limit is required to be applied to

all tanks as indicated by the asterisk contained with Technical Specification 4.21.3.

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JUN 231986

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Should you have any question regarding this matter, please contact G. Yuhas

(FTS 463-3748).

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Ross A. Scarano, Director

Division of Radiation Safety

s- and Safeguards

Enclosure:

Rancho Seco Technical Specifications 3.17.3 and 4.21.3

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G. Cook * '

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RANCHO SECO UN!T 1

TECHNICAL SPECIFICATIONS

Limiting Conditions for Operation

3.17.3 Liquid Holdup Tanks

The quantity of radioactive material contained in each of the

following tanks shall be limited to less than or equal to 10 Curies,

excluding tritium and dissolved or entrained noble gases:

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a. Regenerant Holdup Tanks

b. Outside Temporary Tanks, . ,

l Apolicability At all times

Action

With the quantity of radioactive material in any of the listed tanks

exceeding the above limit, immediately suspend all additions of

radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank

contents to within the limit, and describe the events leading to

this condition in the next Semiannual Radioactive Effluent Release

Report.

Bases

Restricting the quantity of radioactive material contained in the

specified outdoor tanks provides assurance that in the event of an

( . uncontrolled release of the contents, the concentration at the

nearest surface water supply in an unrestricted area would be less

than the limits of 10 CFR 20, Appendix B, Table II, Column 2. There

are two Regenerant Holdup Tanks. The limit applies to each tank '

individually.

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Amendment No. 53

3-72

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TECHNICAL SPECIFICATIONS

.

Surveillance Standards

4. 21 . 3 Licuid . Holdup Tanks *

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the quantity of radioactive material contained in each tank listed in

Sp:cification 3.17.3 shall be detemined to be within the specified limit by

analyzing a mpresentative sample of the tank's contents at least weekly when

radioactive materials are being added to the tank.

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Bases '

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Restricting the quantity of radioactive material contained in the specified -

cutdoor tanks provides assurance that in the event of an uncontrolled release

of the contents, the concentration at the neamst surface water supply in an

unrestricted area would be less than the limits of 10CFR Part 20, Appendix 'B,

Table II, Column 2.

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• Tanks included in this spegification are those outdoor tanks that are not ,

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surrounded by liners, dikes, or walls capable of holding the tank contents iand

that do not have tank overflows and surmunding area drains connected to the l

liquid radwaste treatment system. l

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Amendment No. 53

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[' 4-73

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