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Proposed Tech Specs Re Radiation Monitors & Noble Gas Monitors
	ML20245B321
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/14/1989
From:	; PUBLIC SERVICE CO. OF COLORADO
To:	;
Shared Package
ML20245B316	List: ML20245B313; ML20245B318; ML20245B321;
References
	NUDOCS 8904260017
	Download: ML20245B321 (17)
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1 ATTACHMENT 2 PROPOSED CHANGES f

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'8904260017 PDR 89041 4 "

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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 cortents shall be sampled and analyzec 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 cisposed of as solid waste on an adsorbent material.

f) At least one Reactor Building exhaust fan shall be operating whenever releases frem the gas waste system are taking piact. -

g) Gaseous rac'icactfve effluents released from the plant shall be continuomaly monitored and recorded.

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1) During a?wer operation and/or a release from the gaseous waste toicup system, one noble gas monitor, one halogen monitor, and one particulate monitor and their associated recorders shall be l operable. If any monitor being relied upon to l meet this requirement has only a local alarm, the I monitor shall be checked at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months i to verify it is not alarming. If it is alarming l the release shall be terminated immediately. Use l of a noble gas, halogen, or particulate monitor j having only a local alarm shall be limited to 90 l days.

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Fort St.-Vrain #1 l Technical Specifications l Amendment No.

Page 8.1-4 l l 2) _If the required halogen monitor or the required l particulate monitor becomes inoperable, power l l operation and/or gaseous effluent releases from l

the Reactor Building ventilation system may l continue, provided a s. ample of the effluent stream l 15; continuously collected. The samples shall be I i

l obtained at least on:e per seven days. Once j j

l cbtained, tne samples shall be analyled within 48 l hours.

If the recorder becomes inoperable, releases may continue provided the count rate of etch operable monitor is recorded at least once per four hours during actuel 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 once per eight hours and these samples' are l analyzed for noble gas activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the recorder becomes inoperable, releases may continue provided the count rate of each operable monitor it recorded at least once per four hours

.during actual releases.

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", Fort St. Vrain 01-Technical Specifications-Amendment No.

Page 8.1-5 l 4) If .the required noble gas monitor becomes inoperable, gaseous effluent releases from the gas-waste: holdup system may continue, provided that prior to the release:

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(a)~ Ouplicate samples of the gas waste holdup system contents- are analyzed per ELCO 8.1.1.d) and 1

(b) At least two technically qualified members of d

o the facility staff independently verify the release rate calculations and discharge valve -

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7ineup.

5) If the gaseous waste holdup system effluent flow rate measuring devices or the Reactor Building ;

i exhc.ust stack ficw rate measuring device become l inoperable, releases may continue, provided the i

flow rate is estimated at least once per four j 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 pressure decay evaluation.

Fort St. Vrain #1

'. Technical Specifications Amendment No.

Page 8.1-6

6) If the gas waste header noble gas activity monitor becomes inoperable, gaseous effluent releases may continue, provided a daily grab sample is taken and analyzed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for gamma activity or the effluents are diserted to the gas waste surge tank. If the recorder becomes inoperable, releases may continue provided the count rcte of each operable monitor is recorded at least once per four hours during actual releases.

l 7) If, during power operation, the steam jet air ejector discharge monitor becomes inoperable, the reactor must be shut down within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If there is indication of a primary to secondary leak through the steam generator reheater section, a grab sample shall be 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 I effluent monitors operable, return the minimum required I monitors to operable status within 7 days, and, if I unsuccessful, the failure to correct the inoperability

Fort St.'Vrain #1

.. Technical Specifications.

Amendment No.

Page 8.1-7 l shall be explained in a Special Report within 14 l days of the event. This report will outline tt.e -

l cause of the inoperability, actions taken and the i schedule for restoring the system to an operable l status.

h) The' air dose cue to noble gases released in gaseous effluents at the unrestricted area will be limited to 5 millirad gamma and 10 millirad beta during any calendar l quarter and 10 millirad gamma and 20 millirad 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.

1) The dose rate due to radioactive materials released in gaseous effluents from the site to unrestricted areas shall be limited to the following:

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 l

l 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-Technical Specifications.

. Amendment No.

Page 8.1-9

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NOTE: The channel functional test shall also demonstrate l' that-the Control Room or local alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm setpoint.

2. Circuit failure.

3. Instrument indicates a downstale failure.

l The initial channel calibration shall be performed using one or more reference standards certified by 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 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. (Previously l

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l. Fort St. Vrain #1 Technical Specifications I ~4

. Amendment No.'

!] Page 8.1-10 establi,hed calibration- procedures- may be substituted 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 I thereafter while the tank remains in service. A gamma spectral' analysis shall be. performed on these samples l

l within 48' hours.

e) .The on-line vent iodine /part.iculate monitor filter o shall be analyzed for gross alpha activity, gross beta 1

(' activity, and . principal gamma emitting nuclides once per week to determine that releases are in compliance with ELCD 8.1.1.a) and b), Analysis for Sr-89 and Sr-90 will be done when the gross beta activity exceeds three times the lower limit of detection.

f) The on-line vent iodine / particulate monitor iodine l

cartridge shall be analyzed weekly for 1-131 to determine that releases are in compliance with l ELCO 8.1.1.b).

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Fort St. Vrain #1

-- Technical Specifications Amendment No.

[ Page 8.1 I- Specification ESR 8.1.2 - Radioactive Liquid Effluent, Surveillance Requirements n a) The level alarms and pump interlocks on the two. liquid L

waste receiver tanks and monitoring tank shall be tested once per year.

L b) The liquid effluent discharge blocking valve shall be functionally tested prior to each release or once a l

^ month, whichever is more frequent.

c) The activity monitors of the liquid effluent discharge line and the Gas Waste Compressor Cooling Water System,

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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 release; channel checked during each release, and !

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 38 months and following maintenance on the detector system.

d) Flow rate monitors and activity recorders shall be l channel checked during each release, functionally .!

tested quarterly, and calibrated once per 18 months, i NOTE: The channel functional test shall also

.l. demonstrate.that Control Room or local alarm annunciation occurs if any of the following ;

conditions exists:

1. Instrument indicates measured levels above I the alarm setpoint. j i

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Fort St. Vrain #1

[

Technical Specifications

([l1 . Amendment No.

Page 8.1-24

2. Circuit failure.

3. Instrument indicates a downscale failure.

l The initial channe1' calibration shall be performed using one or more reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from surnliers that participate in measurement assurance activities with NBS. These standards shall permit calibrating the system over its intended range of energy and measurement. For subsequent channel f

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which l

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'l ATTACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION ,

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l SIGNIFICANT HAZARDS CONSIDERATION I. EVALUATION The changes to ELCO 8.1.1.g)1) include a requirement for a four hour check of any relied upon monitor having only a local alarm-and a 90 day time limit. Currently, if the halogen or the particulate monitor becomes inoperable, gaseous effluents may continue to be released from the reactor building vent system provided the effluent is continuously monitored with auxiliary sampling equipment. For noble gas, a grab sample taken every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and analyzed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is required when no alarmed monitor is available. These requirements will be maintained.

The local alarming monitors are installed as backup ventilation exhaust monitors and powered from the Alternate Cooling Method (ACM) bus (Refer to FSAR 11.2.3.1.3). The requirement to check the local alarm Ponitors every four hours will ensure any abnormal release is disccvered and the problem corrected promptly. The 90 day time limit on use of local alarming monitors will allow monitors which alarm in the Control Room to be repaired without unnecessarily reverting to the grab sample mode.

The change to ELCO 8.1.1.g)2) clarifies the action when the required halogen and particulate monitors are out of service.

Power operation and effluent releases may continue provided a continuous sample is collected. The sample will be obtained for analysis every 7 days and that analysis will be performed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . These changes are in accordance with the intent of the Standard Technical Specifications.

The changes in ELCO 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 tne 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 monitor. Additionally, the requirement to take eight hour grab samples and analysis within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not altered.

The grab samples will be taken if the required noble gas monitor l becomes inoperable.

l The change to ELCO 8.1.1.g)8) is in .ccordance with commitments made as part of Public Service Company of Colorado's response to 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.

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a The clarification of which instruments are to be reported for extended periods of inoperability is also included in ELCO 8.1.1.g)8). This is consistent with the wording in the Standard Technical Specifications and PSC letter from Warembourg to Eisenhut, dated 2/9/84 (P-84046).

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 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 7 days or more is it necessary to perform this test. 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to corolete the analysis of this sample is more definitive than the previous "as soon as practicable".

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. The switch is spring loaded and will automatically return to

" MEASURE" If the switch malfunctions and remains in one of the other two possible positions, either a high radiation alarm will be received in the Control Room or the monitor's background count will be artificially elevated while it continues to measure effluent radiatier, 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 cf the switch for downstale failure, high count rate, and circuit failure will continue to be performed.

II. CONCLUSION Based on the above evaluation, it is concluded that operation of Fort St. Vrain in accordance with the proposed changes will not (1) involve a significant increase in the probability or the possibility of a new or different kind of accident from any accident previously evainted,(2) create the possibility of a new or different kind of acciaent from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this thange will not increase the risk to the health and safety of the public nor does it involve any significant ha;:ards consideration.

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4 ATTACHMENT 4.

SAFETY ANALYSIS

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SAFETY ANALYSIS

1. INTRODUCTION This Safety Analysis discusses the changes in this Technical Specification Amendment Request. There changes to ELC0 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)1) - This section of the specification is being changed to add the option of using monitors which are presently installed, but only equipped with local alarms and recorders.

Since the monitors with local alarms will be checked every four hours when relied upon to meet the ELC0 8.1.1.g)1) requirements, no system modifications occur, and no allowable release quantities or release rates are altered, it has been determined that no unreviewed safety question has been created as a result of this change.

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 normal station procedures, ESR 8.1.1.e) and 8.1.1.f), and manu'acturer's recommendation for filter change out. The requirement to analyze the sample within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (consistent with the Standard Technical Specifications) of being obtained will provide timely information about the sample without unnecessarily restricting plant 'perations and personnel. It is concluded that specifying the collection time for the required halogen or particulate monitor 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 sampling equipment is now considered to be one of the acceptable noble gas monitors.

The action to take grab samples and analyze the samples within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when all monitors are inoperable will remain.

Therefore, no change to the requirement or action occur; 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.

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ELC0 8.1.1.g)8) The requirements for restorin.1 and reporting inoperable radioactive gaseous effluent monittes are being changed to be in compliance with Section II.F.1.' of Generic Letter 83-37 (G-83403). This change'is also covered -under a commitment made in PSC letter from Brey to Calvo, datad 5/15/87 (P-87133). The changes to restoration time, reporting requirements and reporting time are in the co".se rva ti ve direction. Therefore, no unreviewed safety question occurs as a ,

result of this change.

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 applicable to the Fort St. Vrain instruments because, as discussed in LER 87-12, the monitor instrument controls carmot normally be set to 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 measure normally but will have an artificially high background count rate. The other tests as specified in the ESR will continue to be performed, which do verify the control room alarm annunciation. Therefore, no 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 ir.cluded. This area is surveilled once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and any alarm would be acknowledged. The monitors with local alarms also have strip recorders so a release history is acquired.

ESR 8.1.1.d) - This section of ESR 8.1.1 is being changed to 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 from analyzing these samples from as soon as practicable to i

within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is a more definitive requirement, and the samples are such that the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months delay between sampling and analysis which may occur will not effect the analysis l significantly. It is therefore concluded that this change does I

not reduce the requirement for maintaining an accurate Hventory of the gas waste tanks.

ESR 8.1.2.d) - See the analysis of ESR 8.1.1.c) above. The changes are identical.

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III. CONCLUSION The margins of safety for these Technical Specifications are not reduced by these' changes. No changes 1n 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 t Section II.F.I.I. Therefore, the proposed changes do not create or involve an unreviewed safety question.

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ML20245B321

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