ML17335A365

Proposed Tech Specs 3/4.7.7, Sealed Source Contamination & Associated Bases Addressing Revised Testing Requirements for Fission Detectors

ML17335A365
Person / Time
Site:	Cook
Issue date:	12/03/1998
From:	INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17335A364	List: ML17335A363 ML17335A365
References
NUDOCS 9812080066
Download: ML17335A365 (23)

Text

ATTACHMENT 2 TO AEP:NRC:1315 TECHNICAL SPECIFICATIONS PAGES MARKED TO SHOW PROPOSED CHANGES REVISED PAGES UNIT 1 3/4 7-26 3/4 7-27 B 3/4 7-5 B 3/4 7-5a 9812080066 981208 PDR ADOCK 05000815 P PDR'

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,7 PLANT SYSTEMS SURVEILLANCE RE UIREMENTS Conti ued

1. With a half-life greater than 30 days (excluding Hydrogen 3)i and

2. In any form other than gas. J f;ss o~ 4a4c

b. Stored sources not in use Each sealed source shall be tested prior to use or transfer to ancther licensee unless tested within the previous six months. Sealed sources ransferred without a certificate 'indicating the ast date shall e t ted prior to being placed into use. o~gf;ss'on,4g ggfJ Q g;s$ )y~

c. s Startu sources Each sealed startup source shall be tested within 31 days prior to being sub)ected to core flux and following repair or maintenance to the source.

gc4c44 4.7.7.1.3 ~Re orts A Special Report shall be prepared aod submitted to the Commission on an annual basis if sealed source or fission der~on leakage tests reveal the presence of 2 0.005 microcuries of removable contamination.

COOK NUCLEAR PLANT UNIT 1 3/4 7-27 AMENDMENT NO. 69

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~ f 3/4 BASES 3/4.7 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATIONSYSTEM The OPERABILITY of the control room emergency ventilation system ensures that the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITYof this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying, the control room to 5 rem or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50.

The Unit I control room emergency ventilation system operates automatically on a Safety Injection Signal from either Unit I or Unit 2. The automatic start from Unit 2 is only available when the Unit 2 ESF actuation system is active in modes I through 4 in Unit 2.

The control room ventilation system normally maintains the control room at temperatures at which control room equipment is qualified for the life of the plant. Continued operation at the Technical Specification limit is permitted since the portion of time the temperature is likely to be elevated is small in comparison to the qualified life of the equipment at the limit.

3/4.7.6 ESF VENTILATIONSYSTEM The OPERABILITYof the ESF ventilation system ensures that adequate cooling is provided for ECCS equipment and that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations were assumed in the accident analyses.

The 1980 version of ANSI N510 is used as a testing guide. This standard, however, is intended to be rigorously applied only to systems which, unlike the ESF ventilation system, are designed to ANSI N509 standards. For the specific case of the air-aerosol mixing uniformity test required by ANSI N510 as a prerequisite to in-place leak testing of charcoal and HEPA filters, the air-aerosol uniform mixing test acceptance criteria were not rigorously met. For this reason, a statistical correction factor will be applied to applicable surveillance test results where required.

3/4.7.7 SEALED SOURCE CONTAMINATION TIMimitatio~~al~ure~emovabl~ntanmmtio~is~~otaWxxl~rindividu6@rgaairradiation material. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, are based on 10 CFR 70.39(c) limits for plutonium. Quantitiere&interest-t~~peeiAeation-vtthieh-are+xempt

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COOK NUCLEAR PLANT-UNIT I Page B.3/4 7-5 AMENDMENT444, 444, 4', 218

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3/4 BASES 3/4.7 PLANT SYSTEMS 3t4.. SEALED SOURC CONTAMINATION ontinued and 70.19. Leakage from source excluded from the re irements of this sp 'catton is not like to represem more than on imum permissibl ody burden for tot y irradiation if source material is 'led or ingested.

3/4.7.8 HYDRAULICSNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads.

Snubbers excluded from this inspection program are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.

COOK NUCLEAR PLANT-UNIT 1 Page B 3/4 7-5a AMENDMENT 159

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ATTACHMENT 3 TO AEP:NRC:1315 PROPOSED TECHNICAL SPECIFICATIONS PAGES REVISED PAGES UNIT 1 3/4 7-26 3/4 7-27 B 3/4 7-5 B 3/4 7-Sa

3/4 LIMITINGCONDITIONS FOR OPERATION AND SURVEILLANCEREQUIREMENTS 3/4.7 PLANT SYSTEMS 3/4.7.7 SEALED SOURCE CONTAMINATION LIMITINGCONDITION FOR OPERATION 3.7.7.1 Each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material, shall be free of 2 0.005 microcuries of removable contamination.

APPLICABILITY: At all times.

ACTION Each sealed source with removable contamination in excess of the above limits shall be immediately withdrawn from use and:

1. Either decontaminatedand repaired, or

2. Disposed of in accordance with Commission Regulations.

b. The provisions of Specification3.0.3 and 3.0.4 are not applicable.

SURVEILLANCERE UIREMENTS 4.7.7.1.1 Test Re uirements - Each sealed source shall be tested for leakage and/or contaminationby:

a. The licensee, or

b. Other persons specifically authorized by the Commission or an Agreement State.

The test method shall have a detectionsensitivityof at least 0.005 microcuriesper test sample.

4.7.7.1.2 Sources in use excludin startu sources and fission detectors reviousl sub'ected to core

~flux - At least once per six months for all sealed sources containing radioactive materials COOK NUCLEAR PLANT-UNIT1 Page 3/4 7-26 AMENDMENT

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3/4 LIMITINGCONDITIONS FOR OPERATION AND SURVEILLANCEREQUIREMENTS 3/4.7 PLANT SYSTEMS SURVEILLANCERE UIREMENTS Continued

1. With a half-life greater than 30 days (excluding Hydrogen 3), and

2. In any form other than gas.

Stored sources not in use - Each sealed source and fission detector shall be tested prior to use or transfer to another licensee unless tested within the previous six months. Sealed sources and fission detectors transferred without a certificate indicating the last test date shall be tested prior to being placed into use.

days prior to being subjected to core flux and following repair or maintenance to the source.

4.7.7.1.3 ~Re rts - A Speeiai Report shall be prepared and submiuedto the Commission on an annual basis tf sealed source or fission detector leakage tests reveal the presence of 20.005 microcuries of removable contamination.

COOK NUCLEAR PLANT-UNIT1 Page 3/4 7-27 AMENDMENT@9

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3/4 BASES 3/4.7 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATIONSYSTEM The OPERABILITY of the control room emergency ventilation system ensures that the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITYof this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50.

The Unit 1 control room emergency ventilation system operates automatically on a Safety Injection Signal from either Unit 1 or Unit 2. The automatic start from Unit 2 is only available when the Unit 2 ESF actuation system is active in modes 1 through 4 in Unit 2.

The control room ventilation system normally maintains the control room at temperatures at which control room equipment is qualified for the life of the plant. Continued operation at the Technical Specification limit is permitted since the portion of time the temperature is likely to be elevated is small in comparison to the qualified life of the equipment at the limit.

3/4.7.6 ESF VENTILATIONSYSTEM The OPERABILITYof the ESF ventilation system ensures that adequate cooling is provided for ECCS equipment and that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations were assumed in the accident analyses.

The 1980 version of ANSI N510 is used as a testing guide. This standard, however, is intended to be rigorously applied only to systems which, unlike the ESF ventilation system, are designed to ANSI N509 standards. For the specific case of the air-aerosol mixing uniformity test required by ANSI N510 as a prerequisite to in-place leak testing of charcoal and HEPA filters, the air-aerosol uniform mixing test acceptance criteria were not rigorously met. For this reason, a statistical correction factor willbe applied to applicable surveillance test results where required.

3/4.7.7 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, including alpha emitters, are based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage from byproduct, source, and special nuclear material sources willnot exceed allowable intake values.

COOK NUCLEAR PLANT-UNIT1 Page B 3/4 7-5 AMENDMENT446, 424, 4$ 9, Q4S

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3/4 BASES 3/4.7 PLANT SYSTEMS 3/4.7.8 HYDRAULICSNUBBERS Allsnubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads. Snubbers excluded from this inspection program are those installed onnonsafety-relatedsystems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.

COOK NUCLEAR PLANT-UNIT1 Page B 3/4 7-5a AMENDMENT4$ 9

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C ATTACHMENT 4 TO AEP:NRC:1315 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION

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TO AEP:NRC:1315 Page 1 Evaluation of Si nificant Hazards Consideration The licensee has evaluated this proposed amendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if facility in accordance with the proposed amendment would not:

operation of the

1. involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated;

2. create the possibility of a new or different kind of accident from any previously analyzed; or

3. involve a significant reduction in a margin of safety.

The licensee proposes,to revise technical specification (T/S) 3/4.7,7, "Sealed Source Contamination," and its associated bases to address testing requirements for fission detectors. The proposed changes would provide consistency with the unit 2 T/S requirements and NUREG-0452, "Standard Technical Specifications."

The determination that the criteria set forth in 10 CFR 50.92 are met for this amendment request is indicated'elow.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes clarify testing requirements for fission detectors. When the fission detectors are tested for surface contamination, they do not interface with plant equipment and they do not affect plant operation. The detectors are not assumed to initiate an accident; therefore, the probability of an accident previously evaluated is not changed.

Conducting tests prior to using a new fission detector provides assurance that intake limits will not be exceeded.

There is no change to the nuclear material contained in the detector. The fission detectors are not used to mitigate the consequences of postulated accidents. Therefore, the consequences of an accident remain the same as previously evaluated.

Therefore, involve a itsignificant is concluded that the proposed increase in the changes probability do not or consequences of an accident previously evaluated.

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2. Does the change create the possibility of a new or different type of accident from any accident previously evaluated?

The proposed changes do not affect the design or operation of systems, structures, or components in the plant. There are no changes to parameters governing plant operation, and no new or TO AEP:NRC:1315 Page 2 different type of equipment will be installed. Therefore, it is concluded that. the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3 ~ Does the change involve a significant reduction in a margin of safety?

The proposed changes do not introduce new equipment, equipment modifications, or new or different modes of plant operation.

These changes do not affect the operational characteristics of any equipment or systems.

Therefore, it is concluded that these changes significant reduction in the margin of safety.

do not involve a In summary, based upon the above evaluation, the Licensee has concluded that these changes involve no significant hazards consideration.

ATTACHMENT 5 TO AEP:NRC:1315 ENVIRONMENTAL ASSESSMENT

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to AEP:NRC:1315 Page 1 Environmental Assessment The Licensee has evaluated this license amendment request against the criteria for identification of'icensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. The Licensee has determined that this license amendment request meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c) (9) . This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:

(i) The amendment involves no significant hazards consideration.

As demonstrated in attachment 4, this proposed amendment does not involve any significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

As documented in attachment 1, there will be no change in the, types or significant increase in the amounts of any effluents released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes will not result in significant changes in the operation or configuration of the facility. There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant.

Therefore, there will be no increase in individual or cumulative occupational radiation exposure resulting from this change.

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