ML20206R689

Proposed Tech Specs,Removing Waste Gas Decay Tank Monitor

ML20206R689
Person / Time
Site:	Beaver Valley
Issue date:	04/13/1987
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20206R642	List: ML20206R638 ML20206R663 ML20206R689
References
NUDOCS 8704220219
Download: ML20206R689 (7)

Text

.

ATTACHMENT A

Revise the Technical' Specifications as follows:

Remove Page Insert Page 3/4 3-62 3/4 3 3/4 3-64 3/4 3-64 3/4 3-66 3/4 3-66 3/4 11-20 3/4 11-20 4

i 8704220219 870413 DR ADOCK 05000 34

m TABLE 3.3-13 (Continued) m RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTTION 5

Q MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION C

3 4.

Waste Gas Decay Tanks Monitor a.

Oxygen Monitor (2)

Oxygen 31 (O -AS-GW-110-1,2) 2 E

e 8m 81 5"

50

%O

• • During waste gas decay tank filling operation.

TABLE 3.3-13 (Continued)

ACTION STATEMENTS ACTION 31 -

With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, operation of this system may continue provided grab samples are obtained every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and analyzed within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during additions to a tank.

ACTION 32 -

With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases.

via this pathway may continue provided samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2 or sampled and analyzed once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

1 1

1 1

BEAVER VALLEY - UNIT 1 3/4 3-64 PROPOSED WORDING

,n

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m,,,.

n.,,-,

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TABLE 4.3-13 (Continumd)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS

$ey CHANNEL K

CHANNEL SOURCE CHANNEL FUNCTIONAL i

INSTRUMENT CHECK CHECK CALIBRATION TEST 3

b.

Particulate Activity Monitor W

N/A N/A N/A g

c.

System Effluent Flow Rate D

N/A R

Q Measuring Device (FR-VS-112) mw O

d.

Sampler Flow Rate Measuring D

N/A R

Q

@w Device MN U#

4.

Waste Gas Decay Tanks Monitor bY Wm a.

Oxygen Monitor D

N/A Q(4)

M 3*

(O -AS-GW-110-1,2) 2 5

RADIOACTIVE EFFLUENTS GAS STORAGE TANKS LIMITING CONDITION FOR OPERATION 3.11.2.5 The quantity of radioactivity contained in each gas storage tank shall be limited to <52,000 curies noble gases (considered as Xe-133).

APPLICABILITY:

At all times.

ACTION:

a.

With the quantity of radioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and 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 b.

Submit a Special Report to the Commission within 30 days pursuant to specification 6.9.2 and include a schedule and a description of activities planned and/or taken to reduce the contents to within the specified limits, c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.5.1 The quantity of radioactive material contained in each gas storge tank shall be determined to be within the above limit at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radicar tive materials are being added to the tank.

Performance of this surveillance is required when the gross concentration of the primary coolant is > 100 pCi/ml.

BEAVER VALLEY - UNIT 1 3/4 11-20 PROPOSED WORDING

ATTACHMENT B

Proposed Technical Specification Change No. 136-No Sionificant Hazard Evaluation g

~

Description of amendment request:

The proposed amendment.would remove the-Waste Gas Decay. Tank Monitor (RM-GW-101) from Tables 3.3-13 and 4.3-13, revise surveillance requirement 4.11.2.5.1 and delete surveillance requirement 4.11.2.5.2.

1.

Page 3/4 3-62, Table 3.3-13, delete items 4.b and 4.c which j

reference RM-GW-101 and the applicable sampler flow rate measuring device.

2.

Page 3/4 3-64, Table 3.3-13, delete Action 35 since this Action statement only applies to RM-GW-101.

3.

Page 3/4 3-66, Table 4.3-13, delete items 4.b and 4.c to reflect the change to Table 3.3-13.

4.

Page 3/4 11-20, surveillance requirement 4.11.2.5.1, clarify this surveillance by removing reference to the Waste Gas Decay Tank-Monitor (RM-GW-101) and replacing with

" Performance of this surveillance is required when the gross concentration of the primary coolant is 100 pCi/ml."

Delete surveillance requirement 4.11.2.5.2 to reflect removal of RM-GW-101.

Basis for no _significant hazards determination:

The proposed changes do not involve a significant hazards consideration because plant operation in accordance with these changes would not:

1.

Involve a

significant increase in the probability of occurrence or the consequences of.a previously evaluated accident-because:

UFSAR Section 14.2.3, Accidental' Release of Waste Gases, provides an analysis for 1% failed fuel with the greatest expected buildup of radioactive fission isotopes in the gas surge tank at approximately 1,780 curies.

This tank was chosen as the limiting release path because it-has the highest potential concentration of Xe-133 equivalent (the major dose contributor, due to its high dose factor).

The gases j.

in the gas surge tank are then sent to a waste gas decay tank for holdup (generally 30 days) and subsequent discharge.

Table 11.3-1 of the BVPS-2 FSAR lists an expected gaseous waste source

• erm of 261 curies / year -(total isotopic radioactivity) for the BVPS-1 radioactive gaseous waste system (this was derived using the PWR Gale Code in accordance with NUREG-0017).

Based on the BVPS-2 FSAR analysis results described above, we have calculated a

Xe-133 maximum expected concentration of 375pCi/ml.

The revision to surveillance requirement 4.11.2.5.1 requires l

verification of the quantity of radioactive material contained in i

each gas storage tank at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radioactive materials are being added to the tank and the concentration of the primary coolant is greater than 100 pCi/ml.

s i

1 Atttchment B Pcgs 2 This action will ensure the accident analysis value will not be exceeded and in NUREG-0472, Revision 2 Tables 3.3-13 and 4.3-13 do not-list a radiation monitor or a sampler flow rate measuring device on the -waste gas holdup system.

With RM-GW-101 i operation, no additional information and no increase in the level h

of safety is provided, therefore, deleting this monitor from the l

technical specifications will not affect the probability of occurrence or the consequences of an accident previously evaluated.

2.

Create the possibility of a

new or different kind of accident from any. accident previously evaluated because:

The proposed changes are bounded by the UFSAR accident analysis of Section 14.2.3.

Specifically, proposed surveillance requirement 4.11.2.5.1 will ensure that appropriate sampling is performed so that the UFSAR accident analysis results will not be reached or exceeded.

Thus,- no adverse safety considerations are introduced by this proposed-change to the technical specifications.

Therefore, the probability for an accident or malfunction of a different type than previously evaluated will not be created.

3.

Involve a

significant reduction in the margin of safety because:

Specification 3.11.2.5 restricts the quantity of radioactivity contained in each gas storage tank.

This provides assurance that in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to an individual located at the nearest exclusion area boundary for two hours immediately following the onset of the release will not exceed 0.5 rem.

The specified limit restricting the quantity of radioactivity contained in each gas storage tank was specified to ensure that the total body exposure resulting from the postulated release remained a

suitable fraction of the reference value setforth in 10 CFR 100.11(a)(i).

Therefore, the proposed changes do not affect the technical specification bases and are consistent with the UFSAR accident analyses.

Conclusion The proposed changes will remove RM-GW-101 from the technical specifications and allow the physical removal of this monitor from the plant.

This monitor provides no additional useful information to the plant operators and manual sampling is only required when the RCS coolant activity exceeds 100 pCi/ml.

Th^

storage tanks are limited in radioactive contents by specif__ tion 3.11.2.5 to 52,000 curies each which satisfies the exclusion area boundary dose criteria of 10 CFR 100.

Since it has been determined that this limit cannot be reached, even with 1%

failed

fuel, and sampling will be performed to determine the tank radioactive material content when material is being added to the

tank, removal of the monitor from the technical specifications and the physical removal of the monitor will not affect the safe operation of the plant.

Therefore, based on the above, it is proposed to characterize the change as involving no significant hazards consideration.