ML20235W861
| ML20235W861 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/01/1987 |
| From: | PUBLIC SERVICE CO. OF COLORADO |
| To: | |
| Shared Package | |
| ML20235W836 | List: |
| References | |
| NUDOCS 8710190068 | |
| Download: ML20235W861 (16) | |
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ATTACHMENT 2 PROPOSED CHANGES I
0 67 B710190060%h0 ppg ADOCK ppR P
Fort St. Vrain #1 Technical Specifications Amendment No.
Page 8.1-3 d) Prior to the release of gaseous radioactivity from the gas waste surge tanks, the contents shall be sampled and analyzed for tritium, and a gamma spectral analysis shall be performed to determine that releases will be in compliance with conditions a) and b).
e) Under normal operating conditions, tritium from the hydrogen getters shall be disposed of as solid waste on an adsorbent material, f) At least one Reactor Building exhaust fan shall be operating whenever releases from the gas waste system are taking place.
g) Gaseous radioactive effluents released from the plant shall be continuously monitored and recorded.
- 1) During power operation and/or a release from the gaseous waste holdup system, one noble gas monitor, one halogen monitor, and one particulate monitor and their associated recorders shall be operable.
l 2) If the required halogen monitor or the required l particulate monitor becomes inoperable, power l operation and/or gaseous effluent releases from the Reactor Building ventilation system may l continue, provided a sample of the effluent stream l is continuously collected. The samples shall be l obtained at least once per seven days. Once l obtained, the samples shall be analyzed within 48 l hours.
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Fort St. Vrain #1 Technical Specifications Amendment No.
Page 8.1- 4 I
If the recorder becomes inoperable, releases may continue provided the count rate of each operable monitor is recorded at least once per four hours during actual releases.
l 3) If the required noble gas monitor becomes inoperable, gaseous effluent releases from the Reactor Building ventilation system, exclusive of releases from the gas waste holdup system, may continue, provided grab samples are taken at least j once per eight hours and these samples are l analyzed for noble gas activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
If the recorder becomes inoperable, releases may f
continue provided the count rate of each operable monitor is recorded at least once per r'our hours i during actual releases.
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s p ' Fort St. Urain #11 g , Technical Specifications
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Amendment No.
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thei required l 4 ) -- .If, noble . gas ' monitor becomes-inoperable, gaseous effluent' releases'f. rom-the' gas- -
waste. holdup' system may continue, provided that i prior.to the.' release:
'(a) Duplicate samples of the gas waste holdup; system contents .are analyzed per ELCO 8.1.1.d) and ..
(b) At least two technically qualified members of
, the facility staff independently verify the-release rate calculations and discharge valve "
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- 5) If the gaseous waste holdup :;ystem effluent flow rate measuring devices or the Reactor Building exhaust stack flow rate measuring device becomes inoperable, releases may continue, provided the flow rate is estimated at least once per four hours. The exhaust stack flow rate is-not used in calculating allowable gas waste discharge flow rates; however it can be estimated by observing how many reactor building exhaust fans are operating. Flow rate from the gaseous waste holdup system can be' estimated by performing a j l
pressure decay evaluation.
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Fort St.~ Vrain #1.
1 Technical > Specifications
. Amendment No.-
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O Page 8.1-6
- 16) If Lthe g'as/ waste' header noble gas activity monitor
.becomes; inoperable, gaseous effluen't releases may; i
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, continue, .provided a dailyL grab sample is taken and 3
analyzed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s- for gamma activity- or: 'the .
effluents are diverted to the gas waste surge tank. I f. l the recorder becemes inoperable, releases may continue provided the count rate of each operable monitor is recorded'at.-least once per four hours during; actual:
h; releases.
- 7) .If duringL; power. operation the steamLjet air ejector discharge' monitor becomes inoperable,'the reactor must-be shut- down within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If there is indication
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'of a: primary to secondary leak through the ^ steam
.l generator reheater ~ section, a grab sample shall be l 2
taken at least once per twelve hours and analyzed for !
noble gas activity within twenty-four hours.
l 8) With less than the minimum required radioactive gaseous l effluent monitors operable, return the minimum required l monitors to operable status within 7 days, and, if i l unsuccessful, the failure to correct the inoperability i
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Fort St. Vrain~#1 I ' '
Technical Specifications: ?
- ' ', Amendment No.
Page 8.1 4; O
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- J -l. shall be'; explained in
- a'Special Report'within~14' a :.
l' . days'of.the event. ,This1 report will outline the J- cause of'the inoperability, actions taken and.the: '
- l. schedule for restoring the system to an operable-
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'h) :The air dose 'due to noble gases . released in_ gaseous i-effluents at the ' unrestricted.! area will be limited to 5 millirad gamma and 10 millirad beta during any calendar' s.
quarter. and 10 millirad gamma and.20 mrad beta during any.
calendar year, .In addition, the dose to a member of the ,
public due.to I-131, tritium, and radioactive particulate with half-lives longer than eight days in gaseous effluents will be limited to 7.5 millirem to any organ during any.
calendar quarter and 15 millirem to any organ during any calendar year,
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1)- The dose rate due to radioactive materials released in n . gaseous effluents from the site to unrestricted areas shall be limited to the following:
't For noble gases - less than or equal to 500 millirems per year to the total body and less than or equal to 3,000 millirems per year to the skin.
For I-131, for tritium, and for all radionuclides in particulate form with half-lives greater than eight days -
less than or equal to 1,500 millirems per year to any organ.
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Fort St.:Vrain'#1 .
l,*. Technical Specifications
-Amendment No.-
Page 8.1- 9
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, NOTE: The channel functional test shall also demonstrate 1 1
l' that the Control Room or. local alarm ' annunciation l occurs. if any.of-the following conditions exists:-
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- 1. Instrument indicates. measured levels above 4
the alarm setpoint.
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- 2. Circuit failure. 1 s i.
- 3. Instrument indicates a downscale failure.
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-The initial channel calibration shall'be performed -
using-one or more reference standards certified by l the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in -measurement assurance activities with NBS. These standards shall permit q l
calibrating the system over its intended range of energy and measurement. For subsequent channel '
I calibration, sources that have been related to the initial calibration shall be used. (Previously l
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m" Fort St. Vrain #1:
-Technical Specifications
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. Amendment No.
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.Page 8.1-10
~ established calibration. procedures may be substituted for'this' requirement.)
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Channel check shal1 consist; of veri fying -
,.. indication of flow during periods of release Channel check shall- be 'made at least once per p 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on days on which continuous, periodic, or-batch' releases are made.
-l. d) Whenever .a gas waste tank is in service for 7 days, a
' sample from the gas waste tank in service shall be l- obtained and further samples shall be obtained weekly l: thereafter while the tank remains -in service. A gamma '
l spectral analysis shall be performed on these samples l within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. l e) The on-line vent iodine / particulate monitor filter shall be analyzed for gross alpha activity, gross beta :
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activity, and principal gamma. emitting nuclides once per week to determine that releases are in compliance with ELCO 8.1.1.a) and b). Analysis for Sr-89 and Sr-90 will be done when the gross beta activity exceeds a i
three times the lower limit of detection. A i
y f) The on-line vent iodine / particulate monitor iodine cartridge shall be analyzed weekly for I-131 to 1
determine that releases are in compliance with l ELCO 8.1.1.b).
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Fort.St. Vrain #1 Technical. Specifications 3
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. Amendment No.
Page 8.1- 23 '
Specification- ESR 8.1.2 - Radioactive Liquid Effluent, Surveillance Requirements.
a) .The level alarms and pump _ interlocks on the two liquid:
waste receiver tanks and monitoring tank shall be
' tested once per year.
b)' _The liquid effluent discharge blocking valve shall be functionally tested prior to each release or ' once a month,'whichever is more frequent. ,
1 c) The activity monitors of the liquid = effluent discharge line and the Gas Waste: Compressor Cooling Water System,.
and the low cooling water blowdown flow switch shall be functionally ~ tested . quarterly. The liquid effluent' activity monitors.shall'be source checked prior to each i release; channel checked during each release, and I calibrated once per 18 months and following maintenance on_the detector system. The Gas Waste Compressor Cooling ' Water System monitors shall be channel checked weekly, source checked monthly, and calibrated once.per
- 18 months and following ~ maintenance on the detector -
system, d) Flow rate monitors and activity recorders shall be- !
channel checked during each release, functionally tested quarterly, and calibrated once per 18 months. j j
The channel functional test shall also l
NOTE:
demonstrate that Control Room or local alarm ] i annunciation occurs if any of the following '
conditiens exists:
- 1. Instrument indicates measured levels-above the alarm setpoint.
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Fort St. Vrain #1.
Technical Specifications
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Amendment-No.-
, Page 8.1-24 ' j q
- 2. Circuit failure. .
- 3. Instrument-indicates'a downscale. failure.
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iThe initial-channel calibration'shal1~be performed using one or more: reference standards certified by i
the National. Bureau of Standards (NBS) or using -
standards that have been obtained- from-. suppliers
-that participate in measurement assurance
, activitiesi<ith NBS. These standards.shall~ permit calibrating the system over its' intended range'of energy and measurement. For~ subsequent channel calibration, sources that have been related'to the initial calibration shall be used. (Operating
. plants may substitute previously established calibration procedures for this requirement.)
Channel check shall consist 'of verifying indication of flow during periods of release. Channel check shall be made at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on days on which
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l ATTACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION l
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SIGNIFICANT HAZARDS CONSIDERATION r<
I. EVALUATION .
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.The change' to ELCO 8.1.1.g.2 clarifies the action when the required halogen and particulate monitors ' an out of service.
Power operation and effluent releases may continue provided a- a continuous sample is collected. The sample will be obtained for analysis every 7 days and that analysis will be performed within
~the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. These changes are in accordance with the intent of the Standard Technical Specifications.
The changes in ELC0 8.1.1.g.3 and 8.1.1.g.4 from "both" noble gas monitors to "the required" noble gas monitor are appropriate because- there are more than two noble gas monitors which can ;
serve this function. Only one noble gas monitor is required per '
ELCO 8.1.1.g.1.
The words "or auxiliary sampling equipment" have been deleted from section 8.1.1.g.3 because the devices previously considered to fulfill this requirement are now considered to be among the devices which may be considered to .be. the required noble gas moni. tor. Additionally, the option of eight hour grab samples is not altered. The grab samples will be the backup on noble gas monitor failure.
The change- to ELCO 8.1.1.g.8 is in accordance with commitments made as part'of Public Service Company of Colorado's response to y NUREG-0737 .open items (P-87133). The restoration time of 7 days and requirement for a special report within 14 days, if not-restored in 7 days, is in accordance with the guidance provided in Generic Letter 83-37, Item II.F.1.1.
The clarification of which instruments are to be reported for j extended periods of inoperability is also included. This is consistent with the wording in the Standard Technical Specifications and PSC letter from Warembourg to Eisenhut, dated 2/9/84 (P-84046). 1 1
The change to ESR 8.1.1.d is to clarify when a gamma spectral ;
analysis of a sample from the in service gas waste tank is l required. The purpose of this test'is to maintain an inventory '
of the tanks' equivalent curies (Kr-88). This inventory is taken '
as 'the tanks are taken out of service. Therefore, only when a gas waste tank has been in service for i days or more is it necessary to perform this test. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to complete the ;
analysis of this sample is more stringent than the previous "as ,
soon as practicable". The isotopes are also generally long-lived, and therefore, would not be absent from the sample in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
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As stated in LER-87-012-00, the instrument controls for Fort St.
Vrain's (FSV) Gaseous and Liquid Effluent Monitors cannot be set to a mode other than operate, designated " MEASURE" at FSV. If the switch is operating properly, the switch will automatically return to " MEASURE". If the switch is nct operating properly, either a high radiation alarm will be receised in the CR or the monitor's background count will be artificially elevated while it continues to measure effluent radiation levels. Thus, if the controls are not operating properly and the mode switch is not in the " MEASURE" position, no unsafe condition would result. The testing of the switch for downscale failure, high count rate, and circuit failure will continue to be performed.
II. CONCLUSION j Based on the above evaluation, it is concluded that operation of Fort St. Vrain in accordance with the prcposed changes will not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) increase the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in any margin of safety. Therefore, this change will not increase the risk to the health and safety of the public nor does it involve any significant hazards consideration.
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ATTACHMENT 4 SAFETY ANALYSIS i
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W .-. SAFETY ANALYSIS y
I. INTRODUCTION This ' Safety Analysis will discuss the changes in this Technical
' Specification Amendment Request. These changes to ELCO 8.1.1,.
ESR 8.1.1,, and ESR 8.1.2 stem from a NUREG-0737 commitment, an LER 87-12 commitment, and the need for clarification of portions of the ELCO and ESRs.
II.- ANALYSIS ELCO 8.1.1.g.2 -
This section of the specification is being changed for clarity. As before, power operation and/or . gaseous effluent releases may. continue while a sample is continuously collected. The 7 day collection period is in accordance. with manufacturer's _ recommendation, normal station procedures, and ESR 8.1.1.e and 8.1.1'.f. The requirement to analyze the sample within' 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of being obtained will provide timely information about the sample without unnecessarily restricting plant operations and personnel. It is concluded that specifying the collection time for auxiliary sampling equipment and the time to analyze the sample do not result in an unreviewed safety question. -
ELCO 8.1.1.g.3 - The deletion of "or the release is continuously monitored with auxiliary sampling equipment" is being done to eliminate redundance. The auxiliary sampling equipment is now considered to be one of the potential noble gas aonitors. The action to take grab samples when all monitors are inoperable will remain. Therefore, no change to the requirement or action occurs as a result of this change.
ELCO 8.1.1.g.4 -
The change from "both noble gas monitors become" to "the required noble gas ' monitor becomes" is being made for clarity. There are more than two noble gas monitors which can serve as the required noble gas monitor. Therefore, the requirement to maintain at least one noble gas monitor is unchanged. 1 ELCO 8.1.1.g.8 -
The requirements for restoring and reporting inoperable radioactive gasecus effluent monitors are being I changed to be in compliance with Section II.F.1.1 of Generic j Letter 83 37 (G-83403). This change is also covered under a commitment made in PSC letter from Brey to Calvo, dated 5/15/87 (P-87133). The changes to restoration time, reporting !
requirements and reporting time are in the conservative i direction. Therefore, no unreviewed safety question occurs as a result of this change. <
H,l:; y ESR 8.1.1.c The- requirement to functionally test the alarm when the switch is not set to the indicated position 'has been deleted. The requirement to test this alarm is not appilcable to the Fort St. Vrain instruments because, as discussed in' LER y 87-12, the monitor instrument controls cannot normally be set to 1 the non-operate mode. The handswitches are spring loaded and will. normally. return to the " MEASURE" position.- If for some reason the handswitch is malfunctioning and remains in one of its other two possible positions, the downscale alarm will sound or the monitor will continue to n'easure normally but will have l
. 'an artificially high background count rate. The other tests.as i specified-in the ESR will' continue to be performed, 'which do 1 verify .the control room alarm annunciation. Therefore, no. l unsafe condition will result.from deleting this test.
Since all monitors which may serve this function have local alarms rather than control room alarms, the functional test requirements for the local alarms have been included. This area is surveilled once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and any alarm would ~be I
acknowledged. The~ monitors with local alarms also have strip 1 recorders so a release history is acquired. {
ESR 8.1.1.d - This section of ESR 8.1.1 is being changed to 1 serve'better the purpose for which it is intended,. to maintain:
an accurate gas waste tank inventory when a tank is in service for extended periods, i .e. , 7 days- or longer. An inventory ' of a -
gas waste tank is always performed when a tank is taken out of service'or weekly when it has been in service for 7 days or longer (no gas waste tank will go longer than'7 days without having the activity level of the gas determined). The change l from analyzing these samples from as soon as practicable to !
within 48. hours is a more definitive requirement, and the I samples are such that the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> delay between sampling.and analysis which may occur will not effect the analysis signi ficantly.' It is therefore concluded that this change does j not reduce the requirement for maintaining an accurate inventory {
of the gas waste tanks.
ESR 8.1.2.d -
See the analysis of ESR 8.1.1.c above. The changes are identical.
III. CONCLUSION The margins of safety for these Technical Specifications are not reduced by these changes. No changes in normal plant operations !
will occur as a result of any of these changes. The changes '
have been made to improve clarity, completeness and accuracy, and to comply with the requirements of Generic Letter 83-37 Section II.F.1.1.
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