ML20096H448

Forwards Rev 8 to ODCM for Comanche Peak Steam Electric Station,Units 1 & 2

ML20096H448
Person / Time
Site:	Comanche Peak
Issue date:	05/21/1992
From:	William Cahill, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20096H451	List: ML20096H448 ML20096H457
References
TXX-92245, NUDOCS 9205270229
Download: ML20096H448 (7)

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7UELECTR/C_ May -21. -1992

, Wale J.Cahm,Jr.

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U, S. .Niicleari. Regulatory Cmmissi >n Attnt' Document Control Desm -

[ '; Washington,-DC -20555 ,

SUBJECT:

COMANCHE' PEAK STEAM ELECTRIC STATION (CPSES)

':  : DOCKET NOS.-50"445.AND 50-446

- TRANSMITTAL OF UPDATED:0FFSITE DOSE

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, CALCULATION' MANUAL (ODCM) 'IO SUPPr,RT LICENSIN(>/0PERATION OF UNIT 2 E -~

_ Cintl.emen:

$ :To facil.itate NRC review necessary for the licensing and oper,. tion of CPSES Unit ~2, TU Electric herewith -submits an- updated copy -of the CPSES ODCH. The 1 Jchangesiincorporated~in-this. update of;the ODCM have been approved and are -

^*  : identified as " Revision 8." . The majority--'of the changes in this submittal were specifically; incorporated to support dual. unit ~operatlon. Some additional _ changes -not:specifically-related to dual--unit operation,'are

, Jalsoiincluded. -Algeneral: summary of the changes. included in this updated f1 E version?ofLtheL00CM is attached -

Please-be advised that:all changes identifi)d with this submittal will not

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-become effective =until a future date, tentatively- identified as Unit'2

' initial? criticality. : Prior to implementat'.an .of these changes, the most

- currentr. approved' version of the ODCM for' Unit- 1: operation will remain in Teffect;(currently Pevision 7 approved December'4, 1991).

For 'any! questions: concerning this updated copy of the CPSES ODCM. pisase .

call.Mr,-Connie Wilkerson at (214).812-881" or Mr. Doug Kay at

-(817)f897-5204.

Sincerely, g

'#R ."x- William J.'Cahill, Jr.

. in- By:

[J21 D. R. Woodlan "Q AL Docket Licensing Manager ih2

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. C LW/ds'-

g'- Attachmenti-

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Enclosure'

.o jN Ec:- McL..R. D. Martin', Region IV

Mr. 8. hurray, Region IV.

$2

-Sesident inspectors, CPbES'(2) (clo) \\

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1Mr-,A,;E.,Hol.1an,Npp j ,' L200126

ATTACHMENT TO TXX-92245 (Page 1 of 6)

SUMMARY

OF CPSES ODCM REVISION 8 CHANGES The proposed offsite Dose Calculation Manual (ODCM) change makes revisions to incerporate Unit 2 radioactive effluent release pathways and effluent monitoring instrumentation.

Revisions are made, where applicable, to release limits and calculational methodologies to support 2 unit operations.

In addition, several changes unrelated to Unit 2 are made.

Of these, the mect significant changes are deletion of the methodologies for determining instantaneous setpoints for the stack PIG monitors particulate and icdine channels, revision of the methodology for performing 31 day dose projections and addition of provisions for establishing a flow rate setpoint for liquid effluent releases. The changes included in this ODCM change are discussed in detail below:

A. Unit 2 related chances -

a) Part I. Control 3/4.3.3.4 - The Unit 2 Turbine Building Sump monitor (2RE-5100) and Station Service Water monitors (2RE-4269 and 2RE-4270) are added to the radioact'.ve liquid effluent monitoring instrumentation requirements in Tables 3.3-7 and 4.3-3.

b) Part I, Control 3/4.11.1.1 - In Control 3.11.1.1, the words "from the site" are added to clarify that the concentration limits for liquid effluents are applicable to the combined liquid releases from the ,

site, not from each unit. Item 18.c of Tabla 4.11-1  !

is changed from "CCW Drain Tank" to "CCW Dt' q Tanks," l since there is a tank for each unit.

c) Part I, Bases 3/4.11.1.2, 3/4.11.1.3, 3/4.11.2.2, 3/4.11.2.3 - The wording in these bases regarding p'.oportionment of ef fluents among units sharing radwaste treatment systems is revised to be more plant specific. The previous wording was from standard technical specifications. The intent of this wording is not changed.

d) Part II, Section 1.0 - Changes to the description of the plant are made, as necessary, to reflect 2 unit operation.

e) Part II, Section 1.2.2 - The Unit 2 Turbine Building Sump monitor (2RE-5100) is added to this section.

ATTACHMENT TO TXX-92245 (Page 2 of 6)

SUMMARY

OF CPSES ODCM REVISION 8 CHANGES f) Eprt II, Section 1.2._1 - The Unit 2 Station Service Water monitors (2RE-4269 and 2RE-4270) are added to this section, g) Part II. Section 1.3 - This section is revised to state how compliance with the dose limits for each unit will be demonstrated. This wording is consistent with the wording in the Bases regarding proportionment of effluents among units sharing radwaste treatment systems.

h) Part II. Section 1.4 - This section is revised to clarify that dose projection limits are applicable to each unit.

1) Part II. Table 1.1 and Ficure 1.1 - Unit 2 release pathways and associated rad monitors are added to this table. The additional pathways are the Unit 2 CCW Drain Tank and Station Service Water Trains A and B.

j) Part II. Section 2.0 - Changes are taade to the description of the plant to reflect 2 unit operation, k) Part'II, Section 2.1 and 2.2 - Based on the addition of the Unit 2 Containment gaseous release pathway, a revision to the calculational methodologies for determining the dose rates and alarm setpoints is necessary. The existing methodology calculated setpoints and doue rates based on the total concentration of radioactive materials present in the plant vent stacks from the combined plant vent continuous-release and a batch release. This method for determining the combined concentration in the stacks from the-continuous and batch sources was based on the assumption that only one batch release occurred at a time. For example, a WGDT release and a Containment vent could not occur simultaneously.

Continued use of this methodology for 2 unit operation would require restricting simultaneous releases from Unit 1 and Unit 2 containments. This would present an undesirable operational restraint.

Therefore, the calculational methodology is revised to determine the release rate and corresponding dose rate for each individual release source based on the concentration and flow rate for that source. The dose rates for all simultaneous releases are then summed for comparison to the site dose rate limit. The rad

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ATTACHMENT TO TXX-92245 (Page 3 of 6)

SUMMARY

OF CPSES ODCM REVISION 8 CHANGES monitor alarm setpoints are then calculated based on the total site dose rate- The revised methodology yields the same answers as the existing-methodology, with the exception of tha auxiliary. building vent monitor and containment atmosphere monitor setpoints for WGDT and containment releases, respectively.

Because the existing methodology assumed that only cae batch release was occurring at a time, it was also assumed that.all other release-sources were negligible relative to the batch release. In-the revised methodology, it is assumed that all concurrent releases could potentially contribute equally to the total site release rate-and dose rate. For containment releases, the possible concurrent release sources are Stack A, Stack B, U1-Containment and U2-Containment. For a WGDT release, the possible concurrent release sources are Stack A, Stack B and a WGDT. Thus release factors of 1/4 for containment releases and 1/3 for WGDT releases are used in the revised methodology. The resulting setpoints ,1 determined using the revised methodology will be lower by a factor of 4 for containment releases and by a factor of 3 for WGDT releases. This will ensure that the site dose rate and correuponding release rate limits will not be exceeded for simultaneous releases from multiple sources.

1) Part II, Section 2.3 - This section is revised to i state how comp'_iance with dose limits for each unit will be demonstrated. This wording is consistent with the wording in the Bases regarding proportionment of effluents among units sharing radwaste treatment system.

m) Eart II. Section 2.4 - This section is revised to clarify that dose projection limits are applicable to each unit.

B. Chances not related to Unit 2 -

a) Part I, Control 3/4.3.3.4. Table 3.3-7. Actions 31.and 32 - Clarification regarding the specified LLD's in these actions was-provided in ODCM Appendix G, Supplemental Guidance Statement #1. These actions are revised to incorporate this guidance and Supplemental Guidance Statement #1 is deleted.

1 ATTACHMENT TO TXX-92245 (Page 4 of 6) i

SUMMARY

OF CPSES ODCM REVISION 8 CHANGES b) Eart I, Control 3/4.11.1.1., Table 4.11-1. Notation 3

- Clarification regarding the specified LLD's for dissolved and entrained gases in liquid effluent samples was provided in ODCM Appendix G, Supplemental Guidance Statement #2. Table 4.11-1, Notation 3 is revised to incorporate this guidance and Supplemental Guidance Statement #2 is deletei.

I c) Part I, Surveillance Recuirement 4 11,2.1 - The l wording of this surveillance requirement was revised l to be consistent with the wording of Surveillance i Requirement 4.11.1.1 for liquid effluents. The  ;

existing wording did not clearly refer to sampling and analyzing airborne waste streams for noble gases.

This revision is made for clarification and the intent and requirements of the surveillance are not changed, d) Part I, Control 3/4.12.1, Table 4.12-1. Notation 3 -

The term "'i" is added to the equation for determination of LLD. This term had been inadvertently omitted from the previous revision.

e) Part I, Administrative Control 6.9.1.3 - The sentence requiring that the initial report include copies of reports of the pre-operational monitoring program for at least two years prior to initial criticality is deleted. This requirement was met with the first report submitted for Unit 1. The pre-operational program ended with the initial criticality of Unit 1.

f) Part II, Section 1.0 - Wording is added to this section to describe the methods used for mixing liquid batch releases to assure representative sampling.

Part I, Table 4.11-1, Notation 2 requires that the method for mixing be described in the ODCM. This information was not included in previous revisions.

g) Part II, Section 1.2 - Wording is added to this section to allow for establishing a flow rate setpoint for liquid waste discharges when a flow rate less than the maximum flow rate is used for calculations. This setpoint will ensure that 10CFR20, Appendix B, Table II, Column 2 MPC's are not exceeded. The previous revision required that the maximum flow rate always be used in effluent. calculations and a flow rate setpoint was not required. The establishment of a flow rate setpoint is consistent with the requirements of Control 3/4.3.3.4 for liquid effluent monitoring

instrumentation.

ATTACHMENT TO TXX-92243 (Page 5 of 6)

SUMMARY

OF CPSES ODCM REVISION 8 CHANGES h) Part II. Sections 1.4 and 2.4 - The methodology for performing liquid and caseous 31-day dose projections is revised. The existing methodology divides the quarter-to-date cumulative dose by the number of days into-the quarter and to determine an average dose per day. This dose per day is multiplied by 31 to calculate the 31 day dose projection. By using the quarter-to-date dose, the average dose per day is based on a variable time period. The methodology is revised to use the cumulative dose for the previous 3 month period, rather than the quarter-to-date. This will result in a consistent time period used for determination of average daily dose for dose projections. -

1) Part II. Section 2.0 - This section is revised to include-a more detailed discussion of all gaseous release sources. This information is descriptive in nature and does not affect dose or setpoint calculation methods. ,

j) Part II, Section 2.0 and 2.2'- The methodologies for determining instantaneous setpoints for the stack PIG's particulate and iodine channels is deleted.

Operational experience has shown that determination of setpoints for these monitors is not practical. This change is consistent with the guidance of NUREG-0133 which states that it is not practical to establish '

instantaneous setpoints for integrating type monitors.

Additionally these monitoring channels are not required by the-gaseous effluent monitoring instrumentation requirements established in Control 3/4.3.3.5. The requirement for sampling of particulates and iodines in Table 3.3-8.is met by the particulate and iodine sample collection devices on the WRGM skid. Compliance with the instantaneous release limits for particulates and iodines is demonstrated by calculations based on the analysis of these samples. Therefore, deletion of the methodology for determination of these setpoints will not adversely affect the-existing level of' effluent-control or accountability.

k) Part II. Accendix D .The not discussing parameters used for calculation of goat milk factors is revised to address the Qp parameter. This value was used for R values tabulated in the ODCM, but was not discussed in-the appendix.

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ATTACHMENT TO TXX-92245 (Page 6 of 6)

SUMMARY

OF CPSES ODCM REVISION 8 CHANGEfS

1) Part II, Annendix G, Suoclemental Guidance Statement f.1 - This guidance statement clarifies that it is acceptable to route the CCW Drain Tank contents to the Waste Water Holdup Tanks (WWHTs) to meet batch sampling requirements. Table 4.11-1, Notation 7 already states that sampling of the CCW Drain Tank is not required when it is routed to the WWHT's.

Therefore, this supplemental guidance statement is deleted.

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