NLS8400199, Forwards Radiological Effluent Tech Spec Pages Clarifying Previous Submittals & Incorporating All Amends to OL Through 840601

Forwards Radiological Effluent Tech Spec Pages Clarifying Previous Submittals & Incorporating All Amends to OL Through 840601

ML20090G737
Person / Time
Site:	Cooper
Issue date:	07/19/1984
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Vassallo D Office of Nuclear Reactor Regulation
References
NLS8400199, TAC-08140, TAC-8140, NUDOCS 8407250252
Download: ML20090G737 (10)

Text

g e GENERAL OFFICE Nebraska Public Power District " * "?uEAYs*E"Ss "^!st """

July 19, 1984 NLSS400199 Office of Nuclear Reactor Regulation Operating Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo, Chief

Reference:

1) Letter from J. M. Pilant to D. B. Vassallo dated March 7, 1984, " Proposed Radiological Effluent Technical Specifications"

2) Letter - from J. M. Pilant to D. B. Vassallo dated April 10, 1984, " Revised Pages to Proposed Radiological Effluent Technical Specifications"

Subject:

Revision to Proposed Change No. 7 to Technical Specifications Radiological Effluent Technical Specifications (HETS)

Cooper Nuclear Station NRC Docket No. 50-208, DPR-46 The District submitted an updated revision of RETS in Reference 1 with subsequent NRC Staff questions resolved in the submittal of Reference 2.

Enclosed are updated Technical Specification pages which clarify previous submittals and incorporate all amendments to the Cooper Nuclear Station Facility Operating License up through Amendment 86 issued June 1,1984.

Should you have any questions or require additional information, please contact me. In addition to one signed original, ten copies are submitted for your use.

l Sincerely, k

1. Pilant Technical Staff Mc. nager Nuclear Power Group JMP/grs:emzi9/12 Enclosures ocA fS50$A o%8;gg '

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.. 4.2 BASES (ccnt'd.)

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- The best test procedure of all those examined is to perfectly stagger the tests.- That is, if the test interval is four months, test one or the other channel every two months. This is shown in Curve No. 5. The difference between Cases 4 and 5 is negligible. There may be other arguments, however, that more strongly support the perfectly staggered tests, including reduc-tions in human error.

The conclusions to be drawn are these:

1. A 1 out.of n system may be treated the same as a single channel in terms of choosing a test-interval and

2. more than one channel should not be bypassed for testing at any one time.

The bases for the radiation monitors are contained in the section denoted Environmental / Radiological Effluents.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.21.C (Cont.'d) 4.21.C.6 (Cont'd)

7. Containment! 1) At least once per 31 days a.- ;Whenever the primary containment is during normal operation.

vented / purged, it shall be vented / 2) Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following an purged through the Standby Gas Treat- increase, as indicated by the ment System. With this specification Condenser Air Ejector Noble not satisfied, suspend all venting / Gas Activity Monitor,'of purging of the containment. This greater than 50%, after fac- l specification does not apply to toring out increases due to

. Normal Ventilation, or during start- changes in THERMAL POWER up while performing primary contain- level, in the nominal steady ment inerting.in accordance with state fission gas release Specification 3.7.A.5.b following from the primary coolant.

.a shutdown of greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, b.- The provisions.of Definition J are b. The radioactivity r,te of noble not applicable. The reporting pro- gases at or near the onclet of-visions of Specification 6.5.2 the main. condenser air ejector

'are not applicable, shall be monitored in accordance D. -Effluent Dose Liquid / Gaseous with Table 3.21.A.2.

Applicability: At all times. D. Effluent Dose Liquid / Gaseous

1. Dose Calculations e m

1. - ~ e e se commitment to a (ac-qt ual) member of the public-due t Public contributed by radioactive radiation and radioactive releases material in gaseous and liquid ,

from Cooper Station shall not exceed 75 mrem to his thyroid or 25 mrem effluents shall be calculateI at least once per year in accordance to his' total body or any other with the ODAM in order to verify.

_ body organ during a calendar year.

In the. event the calculated dose- compliance with Specifi-from radioactive material in liquid cation 3.21.D.

or~ gaseous effluents exceeds two. times the limit of. Specification 3.21.B.2.a,-

3.21.C.2.a. or 3.21.C.3.a, prepare and

. submit a Special Report, in lieu of any other report, to the Commission pursuant to Specification 6.5.3 within 31 days

, .which 1) defines actions to be taken to reduce releases and prevent recurrence

, and 2) results of an exposure analysis including effluent pathways and direct radiation to determine whether the dose or dose commitment to'a member of the public due to radiation and radioactive releases from Cooper Station di ring the .

calendar. year through the period covered Eby the calculation was less than limits stated in this Specification. If the estimated dose exceeds the limits stated herein, and if the condition resulting in doses exceeding these limits has not already,been corrected, submission of the Special Report shall be deemed a timely request for a variance in accord with provisions of 40 CFR Part 190, provided

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, =i h LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.21.DL(Cont'd)' 4.21 (Cont'd)

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information specified in 40 CFR

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Part 190.11(b) is included. In that event, a variance is granted until NRC Staff action'on the item is-complete. E. Solid Radioactive Waste

2. The provisions of Definition J are 1. Operating parameters and limits not applicable.. for the solidification of radio-active waste were established dur-E. Solid Radioactive Waste ing preparational testing of the system. Radioactive waste solid-Applicability: During solid radwaste ification shall be performed in

. processing. accordance with established para-meters and limits. In addition, Specification: every 10th batch of dewatered waste will be sampled prior to

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1.- The appropriate equipment of the solidification and analyzed for solid radwaste system shall be oper- pH.

, , ated to process radioactive wasta containing liquid and liquid des- 2. Each drum of solidified or tined for disposal subject to 10 dewatered radioactive waste will CFR Part 61 to a form that mee'ts be inspected, prior to capping, to

_ applicable requirements of 10 CFR, insure that there is no free Part 61.56 before the waste is standing liquid on top of the shipped from the site. colid waste.

2. Suspend delivery to a carrier for 3. The Semiannual Radioactive Mate-transport of any container of rial Release Report in Specifi-waste subject to Specification cation 6.5.1.F shall include the 3.21.E.1 which does not comply following information for radio-with 10 CFR Part 61.56. active solid waste shipped off-site during the report period:

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'3.21 & 4.21 BASES (Cont'd) 3.21.C & 4.21.C . GASEOUS EFFLUENTS (Cont'd)

'3.21.C.4 &'4.21.C.4 Gaseous'Radwaste System l

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Tha OPERABILITY of the gaseous radwaste treatment system and the ventilation exhaust l treatment systems' ensures that the systems will be available for use whenever gaseous j effluents require treatment prior to release to the environment. The requirement '

that the appropriate portions of these systems be used when specified provides ,

reasonable assurance that the releases of-radioactive materials in gaseous erfluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and design objective Section IID of Appendix I to 10 CFR Part 50.

_ The specified limits governing the use of appropriate portions of the systems are specified'as a suitable fraction of the dose design objectives set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

3.21.C.5~&'4.21~.C.5' Hydrogen Concentration This specification is provided to ensure that the concentration of potentially' explosive gas mixtures contained in the waste gas treatment system is maintained below the flammability limits of hydrogen and oxygen. While the Augmented Treatment System is in service the hydrogen and oxygen concentrations are prevented from reaching the flammability limits. Maintaining the concentration of hydrogen below its flammability limit provides assurance thati che releases of radioactive materials will be controlled in confo,rmance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50. -. .

3.21.C.6 & 4.21.C.6- Air Ejector Restricting the gross radioactivity rate of noble gases from the main condenser pro-vides reasonable assurance that the total-body exposure to an individual at the exclusion area boundary will not exceed a small fraction of the limits of 10 CFR-Part 100 in_the' event this effluent is inadvertently discharged directly to the environment without treatment. -This specification implements the requirements of General Design Criteria'60 and 64 of Appendix A to 10 CFR Part 50.

3.21.C 7 & 4.21.C.7 Containment This specification provides reasonable assurance that releases of Iodine from drywell purging during power operations and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after shutdown will not be excessively large, particularly due to Iodine spiking. The exemptions to using the SBGT system

are intended to minimize the time the SBGT system is on line while coolant temperature is. greater than 200*F,'hence to decrease the probability of damage to the SBGT filters that could occur from overpressurization due to a LOCA and the main purge and vent

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valves open.

3.21.D & 4.21.D EFFLUENT DOSE LIQUID / GASEOUS

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This specification is provided to meet the reporting requirements of 40 CFR Part 190.

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.6.5.1.E _(Cont'd)

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c. Summarized and tabulated results lLn the format of Table

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6.5-1 of analyses of' samples required by the radiological environmental monitoring program, and taken during the report period. In the event that some results are not available'for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.. The missing data shall be submitted as soon as possible in a supplementary report.

d. A summary description of the radiological environmental monitoring program including any changes; a map of all samp1-ing locations keyed to a table giving distances and directions from the reactor; and the results of participation in the Inter-laboratory Comparison Program, required by Specification 3.21.G.

F. Semiennual Radioactive Material Release Report

. -1. A report of radioactive materials released from the Station during the preceding six months shall be submitted to the NRC within 60 days after January 1 and July 1 of each year *.

2. lA Semiannual Radioactive Material Release Report shall include the following:

a. A summary by calendar quarter of the quantities of radioactive liquid and gaseous effluents released from the Station. The data should be reported in the format recommended in Regulatory Guide 1.21, Appendix B, Tables 1 and 2.

b. A summary of radioactive solid waste shipped from the Station, including information named-in Specification 4.21.E.3.

c. A summary of meteorlogical data collected during the year shall be included in the Semiannual Report submitted within 60 days after January 1 of each year.

d. A' list and brief description of each unplanned release of gaseous or liquid radioactive effluent that causes a limit in Specification 3.21.B.1.a. 3.21.B.2.a. 3.21.C.I.a. 3.21.C.2.a.

or 3.21.C.3.a to be exceeded.

e. Calculated offsite dose to humans resulting from the release of effluents and their subsequent dispersion in the atmosphere reported in accordance with Regulatory Guide 1.21.

• It shculd be noted that this data has not normally been available to the District within 60 days and a verbal extension has typically been required from the NRC CNS Project Manager.

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TABLE OF CONTENTS (Cont'd)

Page No.

SURVEILLANCE LIMITING CONDITIONS FOR OPERATION REQUIREMENTS f6.2 Review and Audit 220 6.2.1.A Station Operations Review Committee (SORC) 220 A.1 Membership 220 A.2 Meeting Frequency 220 A.3 Quorum 220 A.4 Responsibilities 220 A.5 Authority 221 A.6- Records 221 A.7 Procedures 222

'6.2.1.B' .NPPD Safety Review and Audit Board (SRAB) 222 B.1 Membership 223 B.2-' Meeting Frequency 223 B.3 Quorum ,

223 B.4 Review 223 B.5 Authority 224 B.6 Records- 225 B.7 Audits 225 6.3 Procedures and Programs 226

6. 3.1. Introduction 226 6.3.2 Procedures' 226 6.3.3 Maintencnce and Test Procedures -

226 6.3.4 Radiation Control Procedures' 226

..A High Radiation Areas 226a 6.3.5 Temporary Changes 226a 6.3.6 Exercise of Procedures 226a

6. 3. 7 , ' Programs .

226a

.A Systems Integrity Monitoring Program 226a

.B Iodine Monitoring Program 226a

.C Environmental Qualification Program ~ 226a 6.4 Record Retention 228 6.4.1 5 year retention 228 6.4.2 -Life retention 228 6.4.3 -2 year retention 229 6.5 Station Reporting Requirements 230 6.5.1 . Routine Reports 230

.A Introduction 230

. B. .Startup Report 230

.C. ' Annual Reports 230

.D Monthly Operating Report 231

, .E Annual Radiological-Environmental Report 231

.F ' Semiannual Radioactive Material Release Report 231a

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TABLE OF CONTENTS (Cont'd) - --

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SURVEILLANCE LIMITING CONDITIONS FOR OPERATION REQUIREMENTS 6.5.2 Reportable Events 231c l 6.5. 3 - Unique Reporting Requirements 235 6.6: Environmental Qualification 235b 6.7 Systems Integrity Monitoring Program 235b

- 6.8 Iodine Monitoring Program 235b 6.9 Process Control Program 235b

-6.10 Offsite Dose Assessment Manual (ODAM) 235c 6.11 Major Changes to Radioactive Waste Treatment Systems 235c 9

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. 6.3. PROCEDURES AND PROGRAMS 6.~3.1 Introduction o

Station personnel shall be provided detailed written procedures to be used for operation and maintenance of system components and systems that could have an effect on nuclear safety.

6.3.2 Procedures Written procedures and instructions including _ applicable check off lists shall be provided and adhered to for the following:

A.- . Normal startup, operation, shutdown and fuel handling operations of the station including all systems and components involving

- nuclear safety.

B. Actions to be taken to correct specific and foreseen potential or actual malfunctions of safety related systems or components including responses to alarms, primary system leaks and abnormal reactivity changes. >

C. Emergency conditions involving possible or actual releases of radio-active materials.

D. Implementing procedures of the Security Plan and the Emergency Plan.  ;

E. Implementing procedures for the fire protection program.

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Administrative. procedures for shift overtime.

G. -Implementing' procedures for the Offsite Dose Assessment Manual.

6.3.3 Maintenance and Test Procedures

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The following maintenance and test procedures will be provided to satisfy

-routine inspection,-preventive maintenance programs, and operating license requirements.

A. Routine testing-of Engineered Safeguards and equipment as reqQired' by the facility License and the Technical Specifications.

B. Routine testing of standby and redundant equipment.

C. Preventive or corrective maintenance of plant equipment and systems that could have an effect on nuclear safety.

D. Calibration and preventive maintenance of instrumentation that could affect the nuclear safety of the plant.

E.- Special testing of equipment for proposed changes to operational procedures or proposed system design changes.

6. 3. 4 - Radiation Control Procedures Radiation control procedures shall be maintained and made available to all .

station personnel. These procedures shall show permissible radiation exposure, and shall be consistent with the requirements of 10 CFR 20.

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6.5.2 R"partrbli Ev.nto A Reportable Event shall be any of those conditions specified in Section 50.73 to 10CFR Part 50. The NRC shall be notified and a report submitted pursuant to the requirements of Section 50.73.

Each Reportable Event shall be reviewed by SORC and the results of this review shall be submitted to SRAB and the Assistant General Manager - Nuclear.

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