TMI-09-148, Response to Request for Additional Information Re License Amendment Request No. 326 to Adopt TSTF-490-A, Rev. 0
| ML093290324 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/24/2009 |
| From: | Cowan P Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TMI-09-148, TSTF-490-A, Rev 0 | |
| Download: ML093290324 (20) | |
Text
{{#Wiki_filter:Exelon Nuclear www.exe]oncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10CFR50.90 TMI-09-148 November 24, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Response to Request for Additional Information Regarding License Amendment Request No. 326 to Adopt TSTF-490-A, Revision 0, "Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement Process"
References:
- 1. Letter from P. Cowan (AmerGen Energy Company, LLC) to the U.S. Nuclear Regulatory Commission, "License Amendment Request No. 326 to Adopt TSTF-490-A, Revision 0, IIDeletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement ProcessII" dated November 6,2008
- 2. TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement Process, dated March 15, 2007
- 3. Federal Register Notice of Availability published on March 15, 2007 (72FR12217)
- 4. Letter from P. Cowan (Exelon Generation Company, LLC) to the U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Request No. 326 to Adopt TSTF-490-A, Revision 0, IIDeletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line ll Item Improvement Process dated July 2, 2009
- 5. Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to C. Pardee (Exelon Generation Company, LLC), "Request for Additional Information Regarding License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-490-A," dated November 5, 2009 By letter dated November 6,2008 (Reference 1), AmerGen Energy Company, LLC, now Exelon Generation Company, LLC (Exelon), requested an amendment to the Technical Specifications (TS) for Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1) consistent with U.S. Nuclear Regulatory Commission (USNRC) approved Industry Technical Specification Task Force Standard Technical Specification Change Traveler, TSTF-490-A, Revision 0, "Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement Process" (References 2 and 3).
U.S. Nuclear Regulatory Commission November 24, 2009 Page 2 of 2 Reference 4 is the TMI, Unit 1 response to a request for additional information regarding the Reference 1 submittal. The USNRC staff has been reviewing the Reference 1 and 4 submittals and has determined that additional information is needed to complete the review. The NRC draft RAI questions were sent via electronic transmission on October 26,2009, to Ms. Wendy Croft of Exelon. The USNRC staff formally issued the RAls on November 5, 2009 (Reference 5). It was requested by the USNRC that Exelon submit a response to the enclosed questions by November 27,2009. Exelon's response to the USNRC questions are provided in Attachment 1 to this letter. Revised mark-ups of the TMI, Unit 1 TS Pages and TS BASES Pages are provided in Attachment 2 to this letter. Exelon has determined that the information provided in response to this request for additional information does not impact the conclusions of the No Significant Hazards Consideration as stated in Reference 1. There are no regulatory commitments contained in this submittal. A copy of this letter and its attachments are being provided to the designated State Official and the chief executives of the township and county in which the facility is located. Should you have any questions concerning this letter, please contact Wendy E. Croft at (610) 765-5726. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of November, 2009. RejlPetfully,
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Pamela B. C(!)wan
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Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC . Three Mile Island, Unit 1 Response to Request for Additional Information Related to Technical Specification Change Request No. 326
- 2. Revised Mark-ups of Technical Specification Pages and TS BASES Pages cc: Regional Administrator, USNRC Region I Project Manager, NRR, USNRC - Three Mile Island, Unit 1 Senior Resident Inspector, USNRC - Three Mile Island Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, Dauphin County, PA R. R. Janati, Commonwealth of Pennsylvania
ATTACHMENT 1 Three Mile Island, Unit 1 Response to Request for Additional Information Related to Technical Specification Change Request No. 326
TMI-09-148 ATTACHMENT 1 Page 1 of 3 NRC Question In the subject LAR, the licensee proposed TS changes to revise Limiting Condition for Operation (LCO) 3.1.4, "Reactor Coolant System (RCS) Activity, "APPLICABILITY requirements and Table 4.1-3, "Minimum Sampling Frequency." The APPLICABILITY requirements are changed to "At all times except REFUELING SHUTDOWN and COLD SHUTDOWN." The proposed change also modifies Item 1.a in Table 4.1-3 to require this surveillance only during POWER OPERATION, even though the APPLICABILITY covers other lower modes. This eliminates the HOT STANDBY, START-UP and HOT SHUTDOWN modes for normal DEX sampling. Similarly, for DEI, Item 1.b.ii is modified to only require sampling during POWER OPERATION, eliminating the START-UP and HOT STANDBY modes. The DEI sampling change is not evaluated by TSTF-490-A, nor is it evaluated in the LAR, beyond a comparison with NUREG-1430 "Standard Technical Specifications Babcock and Wilcox Plants." The NRC staff has a concern about the proposed changes described above. The proposed changes revise conditions for sampling and may exclude sampling during the plant conditions where LCO 3.1.4 may be exceeded. After transient conditions (Le. reactor trip, plant depressurization, shutdown or startup) that end in plant conditions other than POWER OPERATION, sampling is not required to be performed. Radioisotopic spiking and (potentially) fuel failures are more likely to occur because of the transient plant conditions (Le. reactor trip, plant depressurization, shutdown or startup), than at steady state operations. Currently the TMI-1 TSs provide a method for DEI sampling after transients and power changes that change RATED THERMAL POWER more than 150/0. Because LCO 3.1.4 could potentially be exceeded after a plant transient or power change, please justify why sampling for DEX and DEI is no longer needed in the plant conditions or modes that are proposed to be eliminated and justify how the LCO remains consistent with the design bases analysis from which the LCO limits are derived (Le. main steamline break, steam generator tube rupture etc.). Furthermore, please justify why there is an apparent disparity between the modes of applicability (At all times except REFUELING SHUTDOWN and COLD SHUTDOWN) and the limited mode (POWER OPERATION) under which the surveillances are required.
TMI-09-148 ATTACHMENT 1 Page 2 of 3 TMI, Unit 1 Response To resolve the USNRC Request for Additional Information (RAI), Three Mile Island, Unit 1 (TMI, Unit 1) is updating Technical Specification (TS) Page 4-9, (TS Table 4.1-3) to reflect the following:
- 1) Sampling for DEX and DEI in all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN.
- 2) Surveillances for DEX and DEI required in all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN and after transients and power changes that change Rated Thermal Power more than 15% within a one hour period during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN.
The remaining TS Pages, provided by TMI, Unit 1 in the July 2, 2009 RAI submittal, are unchanged and are provided for completeness. TS Change Details The following proposed TS revisions, as stated in the TMI, Unit 1 LAR 326 submittal, Section 2.0, dated November 6, 2008, are being withdrawn:
- 'Wording is also deleted, consistent with SR Table 4.1-3, Item 1.b, to allow entry into STARTUP, HOT STANDBY and HOT SHUTDOWN prior to performance of the SR."
- "Therefore, wording was deleted from TMI Unit 1 TS SR Table 4.1-3 Items 1.a and b to state that the testing shall be conducted only during "POWER OPERATION.""
Based on the above withdrawn revisions, and the USNRC staff questions, TMI, Unit 1 revised TS Table 4.1-3 to reflect the following changes:
- Item 1.a will add a surveillance requirement frequency for DEX sampling after transients and power changes that change RATED THERMAL POWER more than 15% within a one hour period during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN. This surveillance requirement frequency is identical to the proposed requirement for DEI.
- Item 1.b.ii will be required during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN to be consistent with the proposed change to DEX, above.
- Item 1.b.iii will be required during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN to be consistent with the proposed changes above.
TMI-09-148 ATTACHMENT 1 Page 3 of 3 shows the revised markups of the TS Pages and BASES Pages that reflect the TS changes described above. The only TS Page that has changed from the prior TMI, Unit 1 submittals (November 6, 2008 and July 2, 2009) is TS Page 4-9, (TS Table 4.1-3 with applicable Inserts 7, 8, 9, and 10). The remaining TS Pages are unchanged and are being provided for completeness. In addition, the TS BASES (Insert 6) have been updated to reflect the changes listed above.
ATTACHMENT 2 Three Mile Island, Unit 1 Markup of Technical Specifications Pages and TS BASES Pages REVISED TECHNICAL SPECIFICATIONS PAGES vii 1-6 1-8 3-8 3-9 3-9b 4-9
(:;() ~I"rf~() t.. t~E . LIST OF FIGURES FIGURE lIILE
- 2. I-I Core Protection Safety Limit Thfl-l 2-4a 2.1-2 DELETED 2.1-3 Core Protection Safety Bases TMl-l 2-4c 2.3-1 TMI-I Protection System Maximum Allowable Setpoints 2-11 2.3-2 DELETED 3.1-1 Reactor Coolant System Heatup/Cooldown Limitations 3-5a (Applicable thru 29 EFPY) 3.1-2 Reactor Coolant Inservice Leak and Hydrostatic Test 3-Sb (Applicable thru 29 EFPY) I
=:=e:~
3.1-2a ~ 3.1-3 DELETED 3.3-1 Makeup Tank Pressure vs Level Limits 3-24a 3.5-2A DELETED thru 3.5-2M 3.5-1 Ineare .Instrumentation Specification Axial Imbalance Indication 3-39a 3.5-2 IDcore Instrumentation Specification Radial Flux Tilt Indication 3-39b 3.5-3 Incore Instrnmentation Specification 3-39c 3.11-1 Transfer Path to and from Cask Loading Pit 3-S6b 4.17-1 Snubber Functional Test - Sample Plan 2 4-67 5-1 Extended Plot Plan TMI NIA 5-2 Site Topography 5 Mile Radius N/A 5-3 Gaseous Emuent Release Points and Liquid Effluent Outfall Locations N/A 5-4 Minimum Burnup Requirements for Fuel in Region n ofthe Pool A 5-7a Storage Racks 5-5 Minimwn Burnup Requirements for Fuel in the Pool "B" Storage Racks 5-7b 1,r11 Amendmenr Nos. II, t 7, 29. 39, 45, 50, 59. 72, 10f3, lQ9, 120, 126, 134, 142. 150, 114, 167, 1(;8, 1St 211,221, 23iJ-L-
1.9 DELETED
- 1. 10 OELETED 1.11 DELETED 1.12 DOSE EQUIVALENT 1-131 i'liiD9&£....~UIVAl£NT 1-131 shall be thlt c:onclntr.tion of 1-131 (llicrocuri.~- ch 110n. would produce the S'" th r IS th.
quantity and isotopic m 1-131. 1-132 ,-134 and 1-135 actually present. Th. thyroid dose on factors used for this calculation shill be th in Tabl. 14844, *Calculation of Distance Fa ower and Test Rlactor Sites*, (r ~l E-1 of NRC 1(1ta.. . . . .Eory Guid. 1.109, ReYision 1, October 1977.) 1.13 SOURCE CHECK A SOURCE CHECK shall be the qualitattve assess..nt of chann.l rlsponse when the channel sensor is exposed to a radioactiYI sourci. 1.14 DELETED 1.15 OFFSITE DOSE CALCULATION MANUAL (OOCI) Th. OfFSITE DOSE CALCULATION MANUAL (ODe") shall contain the methodology and par. .tlrs used in the calculation of offslte dosls resulting froll radioacttv. gas.ous and liquid .ffluent, in the calculation of gaseous and liqUid .ffluent IIOnttortng Alanl/Trfp Sitpoints, and in the conduct of the Radiological Envtro...ntal Monitoring Protr.. The OOC" sll.11 also cont.tn . (1), thlRadioactive ('flu.nttontrols and Radiologtcal Env1ro....tal
,. .,torlngPr09r. . required by Section 6.8.4 .and (2) descriptions of the info....tion. th,t should be included tn the Annual Radiological Enviro...nta)
Operating and Annual Radioactive Effluent Reliise Reports rlqufrtd by Specifications 6.1.3 and 1.9.4. 1.16 PROCESS CONTROL PRQGMI (PCP) Th' PROCESS CONTROL PROGRM (PCP) shall contafn'the current fo,..,lu, s.,lfn9, Inalysl', test, and d.te,..inations to be ..de to ensun that proc#Ssing and packaging of solid radioactivi wastls based on dlllOftstrattd proclsstng of Ictual or s1.,lated wet solid wlste. will be accOllPlfshed fn such I way IS to assure cOllllPHanc. with 10 CFR 'arts 20, 6J, and 71, StJte regulations, burial ground requir...nts, and other requtr...nts governtn~ the disposal of solid radioactiYI waste,
- 1. 17 GASEOUS lA_STE TREATMENT The GASEOUS RADIIASTE TREATMENT SYSTEM is the s1st. designed and installed to reduce radioactivi gaslous efflulnt by collecting rri&1ry coolant 51st. off gasls fro. the pri.lry syst.. and providing for d. Iy or holdup for the purpose of reducing the total radiolctivity prior to r.leasl to thl environment. .
1-6 Amendment'Ho. 72. IJ7, J7Jt~
Insert 1: DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same thyroid dose when inhaled as the combined activities of iodine isotopes 1-131,1-132,1-133,1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."
1.24 CORE OPERAtING LIMITS REPORT The CORE OPERATING LIMITS REPORT is a TMI-I specific document that provides core opentinglimiU for the current operating reload cycle. These cycle-specific core operating limits sba1I be detenniDed for acta reload cycle in accordance with SpecificadOll 6.9.S. Plant open.tion 'lithia these operating limits is addressed in individual specificadons. . 1.2S FREQUENCY NOTAnON The FREQUENCY NOTAnON specified for the perfOtlDllJCe of Surveillance bquirements shaD correspond to the intervals defined in Table 1.2. AD SurveiJlaDce Requirements shal1 be petfonned within the specified time interval with a maximum allowable extension not co exceed 25 S of the surveillance interval. TIle 2S S extensioa appJiel to aU frequency intervals witb the exception of *P." No extension is allowed for intervals desipa&ed *P." TABLE 1,2 FREQUENCY NOIA'OON NQIArtON fRlQUSNCY S Shiftly (oace Per "2 boon) D . Daily (once per 24* hours) W Weekly (once per 7 days) M MoatbIy (once per 31 days) Q QuIterIy (0CICe per 92 days)
. S/A Semi-AnauaIly (once per 184 days)
R Refue6D, ImetvaJ (once per 24 moatbs) PSIU Prior to eacb leICtOr startup, if aoc done durin, the previous 7 days PS/A WItfdJa six ('I moatbs prior to eada reador startup P Compled prior to tJlCh release N/A(NA) Not appJ.icab1e B Once per 1a moaths P Not to exceed 24 moDths
'1-8 AmeDdmeot No. 12, Ill, ISS, 17J, 17' f~
Insert 2: 1.26 DOSE EQUIVALENT Xe-133 Dose Equivalent Xe-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT Xe-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12.
3.1.4 REMJVR COOLANT SYS~TY 3.1.4.J LIMITING CONDITION fOR OPERATION ~ The s,.eitle aeti'Jity sf the "rim.". eeel8ftt shall he limited teo J2.--
- a. bus ttiaR or ."wal to Q.3S miereeUPieigreJH* DOSE EQUIVALENT 1-1 J I, anel JL-
- b. Le.... ttlan or eqbal to leeJE mieroeuries'patn' .J2--
3.1.4.2 . ",*,PLlliAflIIJIY. at all tillles except .eMlo.s ~~ 3.1.4.3 ACTION: MOMS. 'ow", Opellmoll; SIliiI*Up, Hut Stand~ ~
- i. With the specific activity olthe prim., coolant lIeate. than 8.35 miercctJrie/JIanl DOSe IL I EQUfVAL91T I 131 fer ",ere'" 48 h8ttn** durin. ene eentifttletls ti"'e in'en.1 or e.
Me_ins the limit lifte she..,... 8ft Filtlre 3.1 2a; be in at least HOT SIRJTOO'WN widliu, e...
'heYR. Pet'.., eplRlti9A may 'QAtinu. \VA. DOSE EQUlVA1.ENT I I J J il .levI -e.
9.3S microctifictIU.... e.. It. 'Vi. the 9pdeifie aettvd:y sf the pAm.." eselant .....r diM IOOtl! RliereewFi.~ 1M Q... ill. least HOT SHUTDOWI'I widtift' h.!tJF9. Pern'er eperatien me, continue when ,L pAmAl)' ClaGe).' aQti'Jity is I** diM J~ mieree..rie!l(P'lilft. e...
)4QDiS: ; ..t all times .KG.pc FlAI**iRI. e..
- c. Wid. die specific ..Ii.it, of the prim..,ecolaftt pe:ata'than 9.35 miereeuriellftll' SOia P EQUIVALENT 1-13 J or grcatel than J991E microctlriesfllani perwrm the samplina and IL
......ysis .... iNfRetHs efTabl. 4.1 3 _it the s,.iiie aet;vity atilt. pAlIIary .eel** is I!...
"'8.. 11 te within its Jimits. .e...
=ilj~"J'.it) <<tile pri....,., eo<>Iaftt e._ _ !he NIIII_1I2 hew flel.. 8l1h.-'1 steaJII line hreu aeeiEtcnt with postulated aeeieent intlue.tI steMI g,nerate,
. *. "i.
hi. Sill ""Rdal)' will .. w.1I wi&bia the Put JOO Ii.it f,Uewi"I' ttteeM ,cncqtorbibe naptwe "title", or
'eakele itt eeftjt:llletien 0 an assumH steaEly state p"RlIf)' Ie sHen""" steam generate' leak....... sf 1.9 GPM. The valtle~
eI for the limits on specific aeti,il')" represent limits basetJ ell
- parametrie .ttaluM;ell hy the NR:C of typic. I- Il.
JiteJoeations. These valtlCs are ccnsenative; in dlat die specific site pm.meted ofTMI-I, sueb U site -L bodn"', location and meteoroJolical ccnelitictna; were net eon,icJered ill this c **I. .iell. e-
- E shall be the Ivelage (weighted In proportion to die cOilceubatiOJi cfneh radiontlcfide in.,..e-reactor c:oolalll It the time ofsamp1inl) of the stlm of the ..-erap beta Iftd pmma e..e'lies per ~
ftisifttegratien (in Me'l) for isotepes, other than iodine., with haJfli"es areater than IS millutes, makingap at least 9S% of the total nonoiodine acti. i~ in the eeelant.
- f. The tim. p_Fiae heliRs Rem the tilRe the semple is tae8. ~
Amendment No. L08', m , ~
Insert 3: RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT Xe-133 specific activity shall be limited to:
- a. Less than or equal to 0.35 microcuries/gram DOSE EQUIVALENT 1-131, and
- b. Less than or equal to 797 microcuries/gram DOSE EQUIVALENT Xe-133.
Insert 4: APPLICABILITY: At all times except REFUELING SHUTDOWN and COLD SHUTDOWN. Insert 5: MODES: At all times except REFUELING SHUTDOWN and COLD SHUTDOWN a.1 With DOSE EQUIVALENT 1-131 not within limit, perform the sampling and analysis requirements of Table 4.1.3 until the RCS DOSE EQUIVALENT 1-131 is restored to within limit, AND a.2 Verify that DOSE EQUIVALENT 1-131 is less than or equal to 60 microcuries/gram, AND a.3 Restore DOSE EQUIVALENT 1-131 to within limit within 48 hours. a.4 If the requirements of a.1, a.2 or a.3 cannot be met, be in at least HOT SHUTDOWN within 6 hours and in COLD SHUTDOWN within 36 hours. b.1 With DOSE EQUIVALENT Xe-133 not within limit, restore DOSE EQUIVALENT Xe-133 to within limit within 48 hours. b.2 If the requirements of b.1 cannot be met, be in at least HOT SHUTDOWN within 6 hours and in COLD SHUTDOWN within 36 hours.
Insert 6: LCO The iodine specific activity in the reactor coolant is limited to 0.35 f.tCi/gm DOSE EQUIVALENT 1-131, and the noble gas specific activity in the reactor coolant is limited to 797 ~Ci/gm DOSE EQUIVALENT Xe-133. The limits on specific activity ensure that offsite and control room doses will meet the appropriate 10CFR1 00.11 (Ref. 1) and 10CFR50 Appendix A GDC19 (Ref. 5) acceptance criteria. The SLB and SGTR accident analyses (Refs. 3 and 4) show that the calculated doses are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of a SLB or SGTR, lead to doses that exceed the 10CFR1 00.11 (Ref. 1) and 10CFR50 Appendix A GDC19 (Ref. 5) acceptance criteria. APPLICABILITY In all MODES other than REFUELING SHUTDOWN and COLD SHUTDOWN, operation within the LCO limits for DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT Xe-133 is necessary to limit the potential consequences of a SLB or SGTR to within the 10CFR1 00.11 acceptance criteria (Ref. 1) and 10CFR50 Appendix A GDC 19 acceptance criteria (Ref. 5). In the REFUELING SHUTDOWN and COLD SHUTDOWN MODES, the steam generators are transitioning to decay heat removal and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required. ACTIONS LCO 3.1A.3.a.1 ,a.2, and a.3 With the DOSE EQUIVALENT 1-131 greater than the LCO limit, samples at intervals of 4 hours must be taken to demonstrate that the specific activity is.$. 60.0 ~Ci/gm. The Completion Time of 4 hours is required to obtain and analyze a sample. Sampling is continued every 4 hours to provide a trend. The DOSE EQUIVALENT 1-131 must be restored to within limit within 48 hours. The Completion Time of 48 hours is acceptable since it is expected that, if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period. LCO 3.1A.3.b.1 With the DOSE EQUIVALENT Xe-133 greater than the LCO limit, DOSE EQUIVALENT Xe-133 must be restored to within limit within 48 hours. The allowed Completion Time of 48 hours is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period. LCO 3.1A.3.aA and 3.1A.3.b.2 If the Required Actions of 3.1A.3.a and 3.1.4.3.b are not met, or if the DOSE EQUIVALENT 1-131 is> 60.0 IJCi/gm, the reactor must be brought to HOT SHUTDOWN within 6 hours and COLD SHUTDOWN within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required
Insert 6 (continued) plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE REQUIREMENTS Table 4.1-3, Item 1.a Table 4.1-3, Item 1.a.i requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant at least once every 7 days. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in the noble gas specific activity. Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The 7-day Frequency considers the low probability of a gross fuel failure during this time. The 7-day Frequency is adequate to trend changes in the xenon activity level. The Frequency, between 2 and 6 hours after a power change> 15% RTP within a 1 hour period, is established because the xenon levels peak during this time following iodine spike initiation; samples at other times would provide inaccurate results. If a specific noble gas nuclide listed in the definition of DOSE EQUIVALENT Xe-133 is not detected, it should be assumed to be present at the minimum detectable activity. Table 4.1-3, Item 1.b The Table 4.1-3, Item 1.b surveillance for isotopic analysis for DOSE EQUIVALENT 1-131 concentration is performed to ensure iodine specific activity remains within the LCO limit during normal operation and following fast power changes when iodine spiking is more apt to occur. The 14-day Frequency is adequate to trend changes in the iodine activity level, considering noble gas activity is monitored every 7 days. The Frequency, between 2 and 6 hours after a power change> 15% RTP within a 1 hour period, is established because the iodine levels peak during this time following iodine spike initiation; samples at other times would provide inaccurate results. REFERENCES 1.10CFR100.11.
- 2. Standard Review Plan (SRP) Section 15.1.5 Appendix A (SLB) and Section 15.6.3 (SGTR).
- 3. FSAR, Section 14.1.2.9.
- 4. FSAR, Section 14.1 .2.10.
- 5. 10 CFR 50 Appendix A, General Design Criteria 19
COl' ROlLED C()PY cnON statement pennitting POWER OPERATION to continue for limited time periods w' e prim lant's specific activity greater than 0.35 microcurie/gram DOSE EQUlVALENT J, but within the a able limit shown on Figure 3.1-2a, accommodates possible iodine spiki enomenon which may occur owing changes in llfERMAL POWER. Proceeding to HOT S prevents the release ofactivity should eam generator tube rupture since the saturation pressure of .mary coolant is below the lift ssure of the atmospheric steam relief va'ves. frequency of isotopic analyses fonowi obtained. The NRC statrhas peri eel* a generic analysis of airborne radiation released v .e Reactor Building Purse Isolation Va . The dose contribution due to the radiation contained in the al d steam released through the p isolation valves prior to closure was found to be acceptable provided th of Specifications 3.) .4.1,3.1.4.2 and 3.1 .4.3 are met 3-9 Amendment No. ~, ~. ~
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r FIGURE: 3.1-18 I Dosee *valent 1-131 Primary Coolant Specific Activity Limit Vemu Percent ~, THE .......:AL POWER (with the Primary Coolant Specific Activity >0.35 ....Cilpam E valent 1-131). Amendment No. t.alt J.61 t 204 TED se I j I r
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TABLE 4.1-3 MINIMUM SAMPLING FREQUENCY Item Check Frequency ~ 1. Reactor Coolant a. Speeifie l\eliTotity De~l"flliRftt:ieR Ie eempare le ~ At lesst eRee eaell 7 da3ls d~.ng POWER j).--- i b. I~j IsotopiC Analysis for DOSE EQUIVALENT
~~
i) I ~operations. ~ 1-131 Concentration i ' o~ CoIlewi~ if
=
hllUr!; TIfERMAL POWER change exceeding 15% of ~ RATED THERMAL POWER within a one hour A.- perioo duriftg pewer 6J'e1'8ti6ft; start tip and hot ~
~~~~exeee? I
-- ~1 N nil
- c. RAdioeht:mieftl ffir ~ Dete""iMtiAft JZ...
I
\0 d. Chemistry (CI. F and 02) 5 times/week when Tavg IS GREATER THAN 200°F.
- e. Boron concentration 2 times/week
- f. Tritium Radioactivity Monthly I
~ 2. 3. Borated Water Storage Tank Water Sample Core Flooding Tank Boron concentration Boron concentration Weekly and after each makeup when reactor coolant system pressure is greater than 300 psig or Tavg is greater than 200°F. Monthly and after each makeup when RCS pressure is e- Water Sample greater than 700 psig. Q. o
...,J o
00
;:0 \0
Insert 7: Verify reactor coolant DOSE EQUIVALENT Xe-133 specific activity is less than or equal to 797 microcuries/gram. Insert 8: i) At least once each 7 days during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN. ii) One Sample between 2 and 6 hours following a THERMAL POWER change exceeding 15% of the RATED THERMAL POWER within a one hour period during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN. Insert 9: ii) One Sample between 2 and 6 hours following a THERMAL POWER change exceeding 15% of the RATED THERMAL POWER within a one hour period during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN. Insert 10 iii) # Once per 4 hours, whenever the specific activity exceeds 0.35 J.lCi/gram DOSE EQUIVALENT 1-131 during all plant conditions except REFUELING SHUTDOWN and COLD SHUTDOWN.}}