ML20236Y540

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RM-GW-101 Tech Spec Change Justification
ML20236Y540
Person / Time
Site: Beaver Valley
Issue date: 11/26/1987
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20236Y533 List:
References
NUDOCS 8712140076
Download: ML20236Y540 (11)
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Radiological Controls Department SUBJECT CALC. No: g RM-GW-101 Tech Spec Change Justification ERS- ATL-86-02 5 "G" *b REFERENCE-CO OTHER See Reference Section DCP EM JO Review Category j

@l RSC/OSC Review Required O ll O iii O Other PURPOSE

1) To provide the justification for removal of RM-GW-101 from the Tech Specs l

at BVPS-1.

2) To provide justification for revising Surveillance Requirement 4.11.2.5.1 in the BVPS-1 and BVPS-2 Tech Specs. This justification is to show that grab sampling of the in-service gas storage tank will not be required antil the gross concentration of the primary coolant is >100 uCi/ml.

Revisfnb-1. Add a simplified flow diagram showing RM-GW-101 and the downstream (effluent) noble gas monitor (RM-GW-108B).

2. Revise the analysis regarding bVPS-2 methodology. This revision g assumes that the rupture of one tank at BVPS-2 causes the release of all seven tanks at BVPS-2.
3. Show reductions of max concentrations in decay tanks when correcting for atmospheric pressure at a plant grade elevation of 735 feet.

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DISTRIBUTION Checklist Attachments a DOCUMFNT CONTROL (ERS-xxxl O Purpose O Code t ist O /. sumptions O Print. outs a wrt e RedHealth O Methodology / Derivations O Data Sheets 4 m RedOps m RedEng 8712140076 871202 O input De:s O litustrations PDR ADOCK 05000334 8 p PDR O Resuits/Conce g,e Dept p.

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A >T M ERS-ATL-86-025 l I

Radiobgical Controls Department -

PURPOSE:

The purpose of this calculation package is to provide the justification for

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removal of Waste Gas Decay Tank Radiation Monitor (RM-CW-101) from the Technical Specifications.

ASSUMPTIONS:

1. The Accidental Release of Waste Gas at BVPS-1, ar analyzed in the BVPS-1 Updated FSAR, (Section 14.2.3) is correct as written. (January 1982)  ;

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2. The Waste Gas System Failure at BVPS-2, as analyzed in the BVPS-2 FSAR, (Section 15.7.1) is correct as written. (June 1986)
3. The design case gaseous waste releases at BVPS-1 and BVPS-2, as analyzed in the BVPS-2 FSAR (Tables 11.3-3 and 11.3-4 respectively) are correct as written. (May 1083)

METHODOLOGY / DERIVATION

1. An investigation into the Standard Tech. Specs. (NUREG 0472, Rev 2) {

revealed the following:

A. NUREG 0472. Rev 2, Tables 3.3-13 and 4.3-13 have no reference to a radiation monitor or a sampler flow rat.e measuring device on the l Waste Gas Holdup System, Explosives Gas Monitoring System. f d _However, BVPS-1 Tech. Spec. Tables 3.3-13 and 4.3-13 require  ;

RM-GW-101 and its sampler flow rate measuring device to be operable j during waste gas decay tank filling operations.

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B. NUREG 0472 Rev 2, S.R. 4.11.2.6 states: "The quantity of .

radioactive material contained in each gas storage 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 radioactive materials are being added to the tank."

However, BVPS-1 Tech Spec contain two Surveillance Requirements as follows:

a. S.R.4.11.2.5.1 states: "The quantity of radioactive material t contained in each gas storage 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 radioactive materials are being added to the tank when the l Waste Gas Decay Tank Monitor (RM-GW-101) is not operable."
b. S.R. 4.11.2.5.2 states: "The Waste Gas Decay Tank Monitor (RM-GW-101) operability shall be determined in accordance with l

Tabic 4.3.-13 unless sampling pursuant to 4.11.2.5.1 is being conducted."

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4 page 3 of 11 7Radiological A F Muesne @

Controls Department ERS-ATL-86-025 C. NUREG 0472, Rev-2, L.C.O. 3.11.2.6 states: "The quantity.of radioactivity contained in each gas storage tank shall be Ifmited to less tnan or equal to Curies noble gas (considered as Xe-133)."

l An investigation was coordinated through the INPO Nuclear Network to determine how other plants satisfy the L.C.O.. To date, six responses were received and all these plants do not have rad monitors on their waste gas holdup systems. Consequently, all but one of these plants is satisfying the Curie Limit Tech Spec by daily sampling and analysis of the in-service tank. The other plant satisfies the Curie Limit Tech Spec by stating up-front that as long as the RCS concentration doesn't spike, the specified Curie limit cannot be teached and thus no daily sampling and analysia is necessary.

2. An investigation into the feasibility of relating warte gas decay tank activity lavels to Reactor Coolant System (RCS) concentration (at BVPS-1 and BVPS-2) revealed the following:

A. The BVPS-1 Updated FSAR and the BVPS-2 FSAR concain analyses for accidental release of a Unit 1 gas surge tank and a Unit 2 waste gas decay tank. Thece analyses chow that BVPS-1 and BVPS-2 tanks would hold and subsequently release 1,780 Curies and 20,508 Curies respectively when there is 1% Failed Fuel.

1 S NOTE: The BVPS-1 Updated FSAR was originally performed for a gas surge tank (52 cuft). Since this tank is smaller than each of the three gaseous waste decay tanks (132 cuft), then any /(3 l

one of these BVPS-1 tanks would hold and subsequently release 4,518 Curies when there is 1% Failed Fuel.

This analysis is shown in ATTACHMENT 1.

B. The BVPS-2 FSAR contains the source terms for design case gase-us releases. The system design shows that BVPS-1 and BVPS-2 gaseous waste decay tanks could hold a .aaxiiaum yearly activity per tank of 7,470 Curies and 22,200 Curies respectively. If we conservatively consider these yearly release activities as a single discharge, then the total noble gas concentration for a BVPS-1 and BVPS-2 geseous waste decay tank would be 315 uCi/cc and 160 uti/cc respectively.

NOTE: The above analysis assumes 15 PSIA as the atmospheric pressure. When this value is corrected for plant grade elevation (735 feet) then the total noble gas concentration for BVPS-1 and BVPS-2 gaseous waste decay tanks are reduced to 361 uCi/cc and 153 uCi,cc respectively.

This analysis is shown in /.TTACHMENT 2.

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4, page 4 or 11 AbT M ERS-ATL-86-025 RadL0 logical Controls Department RESULTS/ CONCLUSIONS Based on the above investigations the following recomroendation can be made:

1. RM-GW-101 can be retired. It should be noted that this monitor is not used to saitsify SOCFR20 Noble Gas (Total Body and Skin) Dose Rate limits. These limits are satisfied by Effluent Monitor RM-GW-108B which '

is located downstream of the BVPS-1 and BVPS-2 Waste Gas Decay Tanks. zhh This monitor discharges to the elevated release point (BVPS-1 Cooling Tower: 500 feet). It provides automatic termination of the BVPS-1 or BVPS-2 Waste Gas Decay Tank being discharged upon a High liigh Alarm indication. See sitapli fied flow diagram on ATTACHMENT 3.

NOTE: The BVPS-1 Updated FSAR was originally performed for a gas surge tank (52 cuft). Since this tank is smaller than each of the three gaseous waste decay tanks (132 cuft), then any one of these BVPS-1 tanks would hold and subsequently release 4,158 Curies when there is 1% Failed Fuel.

2. Remove any reference to RM-GW-101 from the Unit 1 Tech Specs as follows:

A. Revise Tech Spec Tables 3.3-13 and 4.3-13 to remove RM-GW 101, its sampler flow rate measuring device and thier associated ACTION STATEMENTS.

B. Revise Tech Spac S.R. 4.11.2.5.1 to removs the following statement:

"when the Waste Gas Decay lank Monitor (RM-GW-101) is not operable."

C. Revise Tech Spec S.R. 4.11.2.5.1 to add the following statement:

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

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NOTE: 100 uCi/ml is a conservative fraction of the most restrictive maximum concentration as calculated on ATTACHMENT 2. l D. Eliminate Tech Spec S.R. 4.11.2.5.2 <

3. Revise the Unit 2 Tech Specs as follows: 1 A. Gevise Tech Spec S.R. 4.11.2.5.1 to add the following statement:

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

4. Revise RCM-RP 6.3 to reflect the Tech Spec changes. This should be i

I completed after NRC approval of the Tech Spec change.

5. Revise RCM-RP 2.1 to remove any reference to RM-GW-101. This should be completed after NRC approval of the Tech Spec change. 1 1

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6. Revise the Shift Tech Daily Work Assignment Sheets for inclusion of a j daill check to ensure that the RCS concentration is <100 uCi/cc, if not,  !

daily sampling of the in-service gas storage tank must resume.

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4 ERS-ATL-86-025 Radiological Controls Department RFFERENCES:

1. BVPS-1 Updated FSAR Section 14.2.3 including Table 14B-10 (January 1982)
2. BVPS-2 FSAR Section 15.7.1 including Table 15.7-3 (June 1986)
3. BVPS-2 FSAR Tables 11.3-3 and 11.3-4 (May 1983)
4. BVPS-1 0.14. Chapter 19, Section 1
5. BVPS-2 0.M. Chapt er 19, Section 1
6. Calculation Package No. ERS-SFL-87-046 1

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4 3 fly, ATTACHMENT 1 P*8* 0

'A@ MN M Radiological Controls Department ERS-ATL-86-025 TABLE 1 "I A Accidental Release of Waste Gas at BVPS;1 The following analysis is from the BVPS-1 Updated FSAR Section 14.2.3 (January 1982)

I 1. The concentration of radioactive waste gases in the reactor coolant system and auxiliary systems is a function of the rate of fission gas l release to the coolant from defective fuel and the rate of rernoval via the auxiliary systems.

2. This waste gaa incident considers a rupture of a gas storage tank with  !

subsequent release of its radioactive gas inventories to the environment

3. Reactor coolant fission product concentrations are based on the assumption that 1.0% of the fuel rods in the core develop pinhole defects, resulting in the diffusien of fission product isotopes into the coolant.

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4. The rod fission produer inventories are those produced at 100% power at a maximum calculated core thermai rating of 2.766 MWt.
5. The reactor corlant letdown rate is 60 GPM.
6. An average of 0.3 scfm of fission gases removed in the degassifier are directed to the gas surge tank prior to being ser.t to a waste gas decay I (auk.
7. The greatest expected buildup of radioactive fission isotopes in the gas surge tank is approximately 1,780 Curies of Xe-133 equivalent (at 80 psi operating pressure).

Using the above analysis we can state that Tech Spec L.C.C. 3.11.2.6 (52.000 J Juries Xc-133) cannot be reached or exceeded considering 1% failed fuel at BVPS-1.

1,780 Curies < T.S. 52,000 Curie limit NOTE: The above PSAR analyses was nriginally performed for a BVPS-1 gas surge tank (52 cuft). The greatest expected buildup of radioactive fission isotopes in a gaseous waste storage tank (132 cuft) would therfore approximately be 4,518 Curies of Xe-133 equivalent.

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" '~ = 2.54 ; 2.54(1,780 Curies) = 4,518 Curies  !

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4,518 Curies < T.S. 52,000 Curie Limit l  !

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MQ ATTACHhENT 1 T%

A M ERS-ATL-86-025 TABLE 1A Radiological Co strois Department l l Accidental Release of Waste Cas at BVPS-1 l When Using The Most Recent Source Date From The BVPS-2 FSAR The-following anal */ sis shows additional data for BVPS-1 waste gas decay rank failure when using the most recent source dats from BVPS-2 FSAR Section 15.7.1 (June 1986)

1. The radions.lide inventories are based on reactor coolant equilibrium concentrations following operation with 1% failed fuel.
2. Letdown flow is processed by the mixed bed demineralizers. One degassifier will process letdown flow at 60 GPM.
3. The inlet line rupture analysis assumes that the noble gas inventory releised to the environment from the ruptured line is based on the sum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release of a fraction of the radioactivity adsorbed cn the charcoal delay beds.
4. It is assumed that 100% of the noble gases produced from the complete degasification of the primary coolant is contained in the seven Gaseous Waste Storage Tanks. The rupture of one tank is assumed to cause the g release of the contents of all seven tanks.

NOTE: At BVPS-1, normal system arrangement does not permit parallel alignment of the three gaseous waste storage tanks. The resultant activity (20,508 Curies) shown in the next step will require division by seven. This shows the greatest expected buildup of radioactive fission isotopes in one gaseous waste storage tank.

5. The greatest expected buildup of radioactive fission isotopes in the seven gaseous waste storage tanks is approximately 20,508 Curies of Xe-133 equivalent.

Using the above EVPS-2 analysis we can state that the BVPS-1 Tech Spec L.C.0 3 11.2.5 (52,000 Curies Xe-133) cannot be reached or exceeded considering 1% failed fuel.

20,500 Curies

= 2,930 Curies per tank <T. . 52,000 Curie Limit 4

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1 N ATTACilMENT 1 AN ERS-ATL-?5-025 TABLE 2 Radiological Controls Department _

Waste Gas System Failu-e at BVPC-2 The following analysis is from the BVPS-2 TSAR Section 15.7.1 (June 1986)

1. The radionuclides inventories are based on reactor coolant equilibrium concentrations following operation with 1% failed fuel.
2. Letdown flow is processed by the mixed bed demineralizers. One degassifier will process letdown flow at 60 GPM.
3. The inlet line rupture analysis ascumes that the noble gas inventory released to the environment from the ruptured line is based on the sum of I hour release of a fraction of the radioactivity adsorbed on the charcoal delay beds.
4. It is assumed that 100% of the noble gases produced from the complete degasification of the primary coolant is contained in the seven Gaseous Waste Storage Tanks. The rupture et one tank is assumed to cause the release of the contents of all seven tanks.
5. The greatest expected buildup of radioactive fission isotopes t.- *he seven gaseous waste st9 rage tanks is approximately 20,508 Curies of Xe-133 equivalent.

Using the above analysis, we can state that Tech Spec L.C.O. 3.11.2.5 (19,000 Curies Xe-133) can be reached when consirlering 3% failed fuel at BVPS-2.

20,508 Curies > T.S. 19,000 Cu ri e s /31

N4. ATTACHMENT 2 I Mh I

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A Radiological Controls Department ERS-ATL-86-025 TABLE 1 n

Design Case Gaseous Waste Release at BVPS-1 The BVPS-2 FSAR Table 11.3-3 (May 1983) lists the design gaseous releases in Curies per year for the Radioactive Gaseous Waste System (Releases of the gaseous waste storage tanks). The listed source terms are as follows:

Kr-85m = 1.8 Ci/yr Kr-85 = 2.2E4 Ci/yr Kr-88 = 2.6E-2 Ci/yr  ;

Xc-131m = 2.4E1 Ci/yr Xe-133m = 4.3E-2 Ci/yr Xe-133 = 3.9E2 C1/yr l TOTAL = 2.24E4 Ci/yr i

1) For purpose of this calculation, the TOTAL Noble Gas Activit y will be considered as Xe-133.
2) The Total Activity in Ci/yr is considered to be spread evenly in each gaseous waste decay tank at BVPS-1:

Max Curies per tank r (2.24E4 Ci/yr) + (3) = 7.47E3 Ci/yr

3) The max total concentration (considered as Xe-133) is based on one gaseous waste deca) tank release:

Max uCi/cc = (7.47E3 Ci)(1E6'" '/Ci) = 375 uCi/cc (704 cuft)(2.83E4 " /cuft)

NOTE: 704 cuft is based on a volume of 4.33 decay tank atmosphere plus 1 volume at atmospheric pressure g

= 4.33 ; [4.33(132 cu.ft) + (132 cu. ft)] = 704 cuft.

4) The max concentration (considered as Xe-133) when correcting for g atmosphe ric pressure at a plant grade elevation of 735 feet

/Ci) = 361 uCi/cc Max uCi/cc = (7.47E3 C1)(1E6 # "

(732 cuft)(2.83E4 /cuf t )

NOTE: 732 cuft is based on a volume of 4.55 decay tank atmosphere plus 1 volume at atmospheric pressure 65 PSIG = 4.55 ; [4.55(132 cuft) + (132 cuft)] = 732 cuft 14.3 PSIA NOTE: BVPS-1 0.M. Chapter 19 Section 1 (Major Components) lists the Gaseous Waste Storage Tanks [ICW-TK-1A, IB and IC] design data as follows:

Capacity = 132 cuft f Operating Pressure = 65 PSIG l l

' 1 g ATTACHMENT 2 l 7A 7 Duquesne @ ERS-ATL-86-025 TABLE 2 page 10 of 11 i Radiological Controls Departrr.ent i

Design Case Gaseous Waste Release at BVPS-2 l The BVPS-2 FSAR Table 11.3 4 (May 1983) lists the design gaseous releases in I Curies per year for the Radioactive Gaseous Waste System (Releases of the gaseous waste storage tanks). The listed source terms are as follows:

I Kr-85m = 3.0E-1 Ci/yr Kr-85 = 2.2E4 Ci/yr.

i Xe-131m = 1.5El Ci/yr Xe-133 = 1.4E2 Ci/yr l TOTAL = 2.22E4 Ci/yr

1) For purpose of this calculation, the TOTAL Noble Gas Activity will be considered as Xc-133.
2) The Total Activity in Ci/yr is considered to be spread evenly in each gaseous waste decay tank at BVPS-2:

Max Curies per tank = (2.22E4 Ci/yr)

3) The max total concentration (considered as Xe-133) is based on all seven gaseous waste decay tanks being released: b '

. Max uCi/cc = (2.22E4 C1)(1E6 uCijpg ) = 1.60E2 uCi/cc

. (4.92E3 cuft)(2.83E4 C"/cu f t')

NOTE: 4.9:'E3 cuf t is based on a volume of i+.33 decay tank atmospheres plus 1 volume at atmospheric pressure times 7 l

= 4.33 ; [4.33(132 cu.f t) + (132 cp.f t)] 7 = 4.92E3 cuf t.

4) The max concentration (considered as Xe-133) when correcting for atmospheric pressure at a plant grade elevation of 735 feet uCi/Cf)

Max uCi/cc = (2.22E4 C1)(1E6 #

= 153 uCi/cc (5.12E3 cuft)(2.83E4 /cuft)

NOTE: 5.12E3 cuft is based on a volume of 4.55 decay tank atmospheres l plus 1 volume at atmospheric pressure times 7

= 4.55 ; [4.55(132 cuf t ) + (132 cuf t)]7 = 5.12E3 cuf t NOTE: BVPS-1 0.M. Chapter 19 Section 1 (Major Componew_s ) lists the Gaseous Waste Storage Tanks [2GWS-TK-25A, 25B, 25C, 25D, 2SE, 25F, 25C] design data as follows:

Capacity = 132 cuft Operaring Pressure = 65 PSIC i

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