ML061010562

50.59 Review, Temporary Configuration Change EC #358522, Addition of Temporary Storage Capacity for the Liquid Radwaste System

ML061010562
Person / Time
Site:	Braidwood
Issue date:	12/15/2005
From:	NRC/RGN-III
To:
References
FOIA/PA-2006-0115
Download: ML061010562 (5)

Text

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LS-AA- 104-1001 Revision 2 50.59 REVIEW COVERSHEET FORM Page I of 5 Station/Unit(s): Braidwood/ Unit 0 Activity /Docurrment Number: Temr orary Conficuration Chanee EC #358522 Revision Number: 0

Title:

Addition of Temporary Storaee Capacity for the Liquid Radwaste System NOTE: For 50.59 Evaluations. information on this fbrm will provide the basis for preparing the biennial summary report mubmitted to the NRC in accordance with the requirements of I0 CFiR 50.59(d)(2).

Description of Activity:

(Provide a brief, concise description of what the proposed activity involves)

Add temporary storage tanks with a combined capacity of less than 400,000 gallons. These tanks will receive water discharged from the radwaste release tanks.

Reason for Actinity:

Discuss why the proposed activity is being performed)

Provide additional storage capacity for the liquid radwaste onsite.

Effect of Activity:

(Discuss how the activity impacts plant operations, design basis, or safety analyses described in the UFSAR.)

The added storage tanks will support continued operation of the plant liquid radwaste system in support of normal plant operation. The design basis of the liquid radwaste system Is maintained, as the only effect is the additional storage capacity. The Braidwood safety analyses are not affected. The radioactivity levels of the water in the temporary tanks are the sarae as the radioactivity of the water that would otherwise have been released to the Kankakee River via the Circulating Water Blowdown line. Based on the expected radioactivity, a conservative evaluation (Reference EC 358522) has concluded that the radiation dose that would result from the postulated rupture of the temporary tanks is bounded by the dose that would be incurred due to the design basis accident analyzed in section 15.7 of the UFSAR. The design basis accident Is the rupture of a Recycle Hold-up Tank.

Each temporary tank will have a berm to address incidental spills. The berm is not meant to contain the entire contents of the tank, since the tank will be located within the Turbine Building and any catastrophic failure of the tank will drain Into the Turbine Building drain system. Per EC #358522, appropriate controls for gaseous releases, in accordance with the Braidwood Offside Dose Calculation Manual (ODCM), will be added to the vents from the tanks. The total radioactivity'released to the environment is not increased by the added storage capacity because the water that is stored Inside the tanks would have been released to the Ka nkakee River.

Summary of Conclusion for the Activities 50.59 Review:

(Provide justification for the conclusion, including sufficient detail to recognize and understand the essential arguments leading to the conclusion. Provide more than a simple statement that a 50.59 Screening, 50.59 Evaluation, or a License Amendment Request, as applicable, is not required.)

The proposed additional storage capacity does not affect the design function of the liquid radwaste system The proposed activity does not involve an adverse change to a procedure that is described in the UFSAR, does not change an element of an evaluation methodology nor does it use an alternate evaluation methodology that is used in establishing the design be sis or in the safety analyses. The proposed activity does not involve a test or experiment. The storage containers do not result in placing the plant in an abnormal mode of operation or introduce any anticipated transients or accidents. The potential rupture of the tanks is bounded by the rupture of a Boron Recycle Hold-up Tank that is evaluated in Chapter 15 of the Braidwood UFSAR. Based on this evaluation, the proposed activity does not require a full 50.59 evaluation nor does it require NRC approval.

The dose consequences of adding the temporary tanks have been addressed as part of EC 358522. Appropriate measures will be taken to contain liquid release/spill from the tanks to prevent spreading to offsite areas. Gaseous releases from the tanks' vent lines will be controlled/monitored in accordance with the provisions of the Braidwood ODCM. The total radioactivity released to the environment is not increased by the added storage capacity because the water that is stored inside the tanks would have been released to the Karkakee River.

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I ' . I LE-AA.104-1001 I0 Revision I 50.59 REVIEW COVERSHEET FORM BRW-S-2005.225 Rev. 0 Page 2 of 5 Attachments:

Attach all 50.59 Review forms completed, as appropriate.

(Note: if both a Screening and Evaluation are completed, no Screening No. is required)

Forns Attached: (Check all that apply.)

Applicability Review 50.59 Screening 50.59 Screening No. BRW-S-2005-225 Rev. 0 50.59 Evaluation 50.59 Evaluation Rev.

No.

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LS-AA-104-1003 Revision I 50.59 SCREENING FORM Page 3 of 5 50.59 Screening No. BRW-S-2005-225 Rev. No. 0 Activity/Document Number: Temporarv Configuration Change EC #358522 Revision Number: C-

1. 50.59 Screening Questions (Check correct response and provide separate written response providing the basis for tht answer to each question)(See Section 5 of the Resource Manual (RM) for additional guidance):

I. Does th: proposed Activity involve a change to an SSC that adversely affects an UFSAR described a YES 0 NO design function? (See Section 5.2.2.1 of the RM)

The liquid radwaste system collects, monitors, and recycles or releases, with or without treatment where appropriate, all potentially radioactive liquid wastes produced by the station during normal operation and maintenance, as well as transient conditions. The system is designed so that liquid radwaste discharged from the site will have radioactive nuclide concentrations well within the limits specified in 10CFR20 and I0CFR50, Appendix 1. The system operates on a batch basis, thus allowing each treated batch to be sampled before releasing.

The addition of storage tanks to hold radioactive water from the release tanks increases the storage capacity of the system. The added tanks thus support the operation of the liquid radwast! system as described in the UFSAR and do not have an adverse effect on the UFSAR design function of the system.

2. Does the proposed Activity involve a change to a procedure that adversely affects how UFSAR 5 YES 0 NO described. SSC design functions are performed or controlled? (See Section 5.2.2.2 of the RM)

The proposed activity does not involve a change to a procedure that adversely affects how the design function of the liquid radwaste system, as described in the UFSAR, is performed or controlled.

Procedures described In the UFSAR do not address storage of processed fluids in temporary containers. Operating the plant with the temporary radioactive water storage tanks will not result in changes to how any design functions described in the UFSAR are performed or controlled.

UFSAR Section 11.2.2.3 addresses the procedure that is used to release processed liquid to the Kankakei! River via the Circulating Water Blowdown line. The added storage tanks will contain liquid that has been processed and is ready for release to the river; the added storage capacity does not prevent the plant from releasing to the river. The process described in the UFSAR is not adversely affected.

The operation of the temporary storage tanks will be addressed via a formal procedure. This procedure does not result in an adverse effect on the design function of the liquid radwaste system or any other system or component.

3. Does the proposed Activity involve an adverse change to an element of a UFSAR described I] YES ED NO evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing the design bases or used in the safety analyses? (See Section 5.2.2.3 of the RM)

Placement and use of temporary water storage containers does not affect any design bases or safety analyses described in the UFSAR. There will be no impact to any fission product barriers or evaluation methodology used to establish any barrier's Integrity. Furthermore, in accordance with Section 5.5.12 of the Technical Specifications and Appendix L of the Braidwood Technical Requirements Manual, administrative requirements exist to control and monitor radioactive releases fram the site to maintain releases below limits.

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i 't LS-AA.-104-1003 Revision I 50.59 SCREENING FORM Page 4 of 5 50.59 Screening No. BRW-S-2005-225 - Rev. No. 0 Activity/Documsnt Number: Temporary Configuration Change EC #358522 Revision Number: 0

4. Does the proposed Activity involve a test or experiment not described in the UFSAR, where an SSC 0 YES Z NO is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR? (See Section 5.2.2.4 of the RM)

The storage containers are passive components that do not cause the plant to be placed in an abnormal mode of operation or introduce any anticipated transients or accidents.. Use of the containcrs does not affect system's design response, or operation. The activity does not involve a test or experiment.

5. Does the proposed Activity require a change in the Technical Specifications or Operating License? Q YES S NO (See Section 5.2.2.5 of the RM)

Technicai Specifications section 5.5.12 and Appendix L of the Technical Requirements Manual, both titlld "Explosive Tanks and Storage Tank radioactivity Monitoring Program", address limitations on radioactivity contained in outdoor liquid storage tanks that are unprotected.

These requirements have been incorporated into the Braidwood Offsite Dose Calculation Manual and are not affected by the added temporary storage capacity.

11. List the documents (e.g., UFSAR, Technical Specifications, other licensing basis, technical, commitments, etc.) reviewed, including sect ons numbers where relevant information was found (If not identified in the response to each question).

UFSAR Revi ;ion 10. Section

• 3.1.2.6.1 Evaluation Against Criterion 60- Control of Releases Radioactive Materials to the Environment

• 11.1 Radioactive Waste Management

• 11.2 Liquid Waste Management System

• 11.5 Process and Effluent Radiological Monitoring and Sampling Systems

• 15.0 Accident Analysis

. 15.7.2. Radioactive Liquid Waste System Leak or Failure (Atmospheric Release)

. 15.7.3 Postulated Radioactive Release Due to Liquid Tank Failure (Ground Release)

UFSAR Revision 10. Table 11.2.4 Comparison of Expected Liquid Effluent Concentrations to 10CFR20 Limits

• 15.0-12 Potential Oftsite Dose due to Accidents - Dose (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) at Exclusion Area Boundary Braidwood Teichnical Specifications

• 5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program (Programs and Manuals)

Braidwood Technical Requirements Manual

• Appendix L Explosive Gas and Storage Tank Radioactivity Monitoring Program Braidwood Off site Dose Calculation Manual

• Appendlix A, Section A.2.4 Tank Overflow

• Table F-I General Information - Limits on Radioactivity in Unprotected Outdoor Tanks Document in PortaVJ

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. 0 LS-AA-104-1003 Revision I 50.59 SCREENING FORM Page 5 of 5 50.59 Screening No. BRW-S-2005-225 Rev. No. 0 Activity/Docutrent Number: Temporary Confi2uration Chanee EC #358522 Revision Number: 9 Il. Select the appropriate conditions:

s rf all questions are answered NO, then complete the 50.59 Screening and implement the Activity per the applicable governing procedure.

a If question 1, 2, 3, or 4 is answered YES and question 5 is answered NO, then a 50.59 Evaluation shall be performed.

El If questions I, 2, 3, and 4 are answered NO and question 5 is answered YES, then a License Amendment is required prior to implementation of the Activity.

O If question 5 is answered YES for any portion of an Activity, then a License Amendment is required prior to implementation of that portion of the Activity. In addition, if question 1, 2, 3, or 4 is answered YES for the remaining portions of the Activity, then a 50.59 Evaluation shall be performed for the remaining portions of the Activity.

IV. Screening Signoffs:

50.59 Screener: John Panici Sign: p° JIL'AI Date: ___i /0 5 (Print name) (Signature) 50.59 Reviewer: S. V. Shah Sign: A- J Date: *2J 'ld (Print name) (Signature)

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