ML20151U925

Proposed Tech Specs Re RCS Specific Activity Reporting Requirements from Special to Annual Rept,Per Generic Ltr 85-19

ML20151U925
Person / Time
Site:	Beaver Valley
Issue date:	02/05/1986
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20151U911	List: ML20151U905 ML20151U919 ML20151U925
References
GL-85-19, NUDOCS 8602110150
Download: ML20151U925 (7)

Text

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REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a. 1 1.0pci/ gram DOSE EQUIVALENT I-131, and

b. I 100/5 pCi/ gram.

APPLICABILITY: MODES 1, 2, 3, 4 and 5 ACTION MODES 1, 2, and 3*

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a. With the specific activity of the primary coolant >1.0 l pCi/ gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in HOT STANDBY with T avg

<500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

b. With the specific activity of the primary coolant > 100/5 l pCi/ gram, be in HOT STANDBY with Tavg < 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

MODES 1, 2, 3, 4 and 5

a. With the specific activity of the primary _ coolant > 1.0 pCi/ gram DOSE EQUIVALENT I-131 or > 100/E pCi/ gram, perform the sampling and analysis requirement of item 4a of Table 4.4-12 until the specific activity of the primary coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS 4.4.8 -The specific activity of the primary coolant shall be determined to be within the limits be performance of the sampling and analysis program of Table 4.4-12.

1 hoh kDO $4 P

• With Tavg 1 500*F BEAVER VALLEY - UNIT 1 3/4 4-18 (next page is 3/4 4-20)

PROPOSED WORDING

. REACTOR COOLANT SYSTEM BASES The ACTION statement permitting POWER OPERATION to continue for limited time periods with the primary coolant's specific activity

> 1.0 pCi/ gram DOSE EQUIVALENT I-131, but within the allowable limit shown on Figure 3.4-1, accommodates possible iodine spiking phenomenon which may occur following changes in THERMAL POWER.

Operation with specific activity levels exceeding 1.0 pCi/ gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limits shown on Figure 3.4-1 must be restricted since the activity levels allowed by Figure 3.4-1 increase the 2-hour thyroid dose at the site boundary by a factor of up to 20 following a postulated steam generator tube rupture.

Reducing T to <500*F prevents the release of activity should a steam avheneratortuberupturesincethesaturationpressure of the primary coolant is below the lift pressure of the atmospheric steam relief valves. The surveillance requirements provide adequate assurance that excessive specific activity levels in the primary coolant will be detected in sufficient time to take corrective action. Information obtained on iodine spiking will be used to assess the parameters associated with spiking phenomena. A reduction in frequency of isotopic analyses following power changes may be permissible if justified by the data obtained.

3/4.4.9 PRESSURE / TEMPERATURE LIMITS All components in the Reactor Coolant System are designed to withstand the effects of cyclic loads due to system temperature and pressure changes. These cyclic loads are introduced by normal load transients, reactor trips, and startup and shutdown operations. The various categories of load cycles used for design purposes are provided in Section 4.1.4 of the~FSAR. During startup and shutdown, the rates of temperature and pressure changes are limited so that the maximum specified heatup and cooldown rates are consistent with the design assumptions and satisfy the stress limits for cyclic operation.

During heatup, the thermal gradients in the reactor vessel wall produce thermal stresses which vary from compressive at the inner wall to tensile at the outer wall. These thermal-induced compressive streses tend to alleviate the tensile stresses induced by the internal pressure. Therefore, a pressure-temperature curve based on steady state conditions (i.e., no _ thermal stresses) represents a lower bound of all similar curves for finite heatup rates when the inner wall of the vessel is treated as the governing location.

BEAVER VALLEY - UNIT 1 B 3/4 4-5 PROPOSED WORDING

ADMINISTRATIVE CONTROLS ANNUAL REPORTS 1 6.9.1.4' Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior. to March 1 of each year. The 'intitial report shall be submitted prior to March 1 of the year following intitial criticality.

6.9.1.5 Reports required on an annual basis shall include:

a. A tabulation of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem /yr and their associated man-rem exposure according to work and job functions 2 (e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, 'and refueling). The dose assignments to various duty-functions may be estimated based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20 percent of the individual total dose need not be acounted for. In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.

b. Documentation of all challenges to the pressurizer power operated relief valves (PORVs) or pressurizer safety valves.

c. The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the'first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radiciodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after. the radiciodine activity was reduced to less than limit.

Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit' was . exceeded; (4) Graph of the I-131 concentration and one other radiciodine -isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radiciodine limit.

1 A single submittal may be made for a multiple unit' site.

The submittal should combine those sections that are commmon to all units at the site.

2 This tabulation supplements the requirements of Section 20.407 of 10 CFR Part 20.

BEAVER VALLEY - UNIT 1 6-14 PROPOSED WORDING

. ADMINISTRATIVE CONTROLS

a. . ECCS Actuation, Specifications 3.5.2 and 3.5.3.

b. Inoperable seismic Monitoring Instrumentation ,

Specification 3.3.3.3.

c. Inoperable Meteorological Monitoring Instrumentation, Specification 3.3.3.4.

d. Seismic event analysis, Specification 4.3.3.3.2.

e. Sealed source leakage in excess of limits, Specification 4.7.9.1.3.

f.- Fire Detection Instrumentation, Specification 3.3.3.6.

g. Fire Suppression Systems, Specifications 3.7.14.1, 3.7.14.2 and 3.7.14.3'and 3.7.14.5.

h. Miscellaneous reporting requirements specified in the Action Statements for Radiological Effluent Technical Specifications.

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i. Containment Inspection Report, Specification 4.6.1.6.2.

6.10 RECORD RETENTION 6.10.l' The following records shall be retained for at least five (5) years:

a. Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities,

'inspec.tions , repair and replacement of principal items of equipment related to nuclear safety.

c. All REPORTABLE EVENTS.

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e. Records of reactor tests and experiments.

f. Records of changes made to Operating Procedures.

g. Records of radioactive shipments.

h.- Records of sealed source leak tests and results.

i. Records of annual physical inventory of all sealed source material of record.

BEAVER VALLEY - UNIT 1 6-23 PROPOSED WORDING

ATTACHMENT B No Significant Hazard Determination Proposed Change Request No. 119 amends the Beavor Valley Power Station, . Unit No. 1 Technical _ Specifications to revise the reporting requirements on RCS specific- activity- from a special report to an annual report in accordance with Generic Letter 85-19.

Description of amendment. request: As part of the continuing effort to delet'e unnecessary reporting requirments, the NRC has determined that the reporting requirements for iodine spiking can be reduced from' a short-term report (Special Report or Licensee Event Report) .to an item to be included in the Annual Report. The information proposed for inclusion in the Annual Report is similar to that' previously. required in- the Licensee Event Report but has been changed to more clearly designate inclusion of the specific. activity analysis results and to delete the information regarding fuel burnup by core region. The following revisions are proposed:

(1) delete Section 3.4.8 Mode 1, 2 and 3* Action statement (a) and the .Special Report specified in Mode 1, 2, 3, 4 and 5 Action statement (a).

(2) move surveillance requirement 4.4.8 from page_3/4 4-19 to page 3/4 4-18, delete page 3/4 4-19 and add a note to page_3/4 4-18 (next page is 3/4 4-20).

(3) acd item (c) to Administrative Control 6.9.1.5 to include the results of specific activity analysis when the primary.. coolant exceeds the limits of Specification 3.4.8 in the Annual Report.

(4) revise Bases-3/4.4.8 to' reflect the new Action statements of Section 3.4.8.

'(5) . delete- Administrative Control 6.9.2.1 to- reflect the change in reporting requirements from Special Report to

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Annual Report.

Basis for no significant hazard consideration determination:

This change is considered to be administrative in nature since the change reflects an NRC effort to eliminate unnecessary technical speci.fication requirements (Generic Letter 85-19). .. The NRC has determined that existing requirements to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. For Beaver Valley, this is specified as 10

, . percent of the units total yearly operating time.

Based on the criteria for defining no significant hazards consideration setforth. in 10 CFR 50.92(c), plant operation in accordance with.the proposed amendment would not: -

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, Attcchment B Page 2.

(1)' -involve a significant increase in the probability of occurrence or the- consequences of an accident or malfunction. of equipment important to safety previously eva'luated. The proposed changes do not involve physical change. to any plant safety.related systems, components or structures. The NRC has' determined that the reporting requirements for iodine spiking can be reduced from a short-term' (Special . Report or Licensee Event Report) to an~. item included in the Annual Report. The information

. proposed for inclusion in the Annual Report is similar-to that previously required in an LER but has been changed

.to' more clearly designate inclusion of the specific activity analysis results and to delete the information regarding fuel burnup by core' region.

The NRC has recognized the fact that the quality of nuclear fuel has greatly improved over the past decade which- results. in normal coolant iodine activity well Lbelow the limit. In addition,'10 CFR 50.72(b)(1)(ii) requires immediate NRC notification of fuel cladding

' failures .that exceed expected values or that are caused by unexpected factors. 'Therefore, the NRC considers this technical specification' limit no lenger necessary on the basis. that proper fuel management and existing reporting requirements should preclude ever approaching the limit.

Based on the above, the. proposed. changes are administrative in nature since the reporting methods have been revised and the coolant activity limit remains unchanged. These changes do not affect ~the accident analyses, therefore, the probability of an occurrence or consequence of an accident or malfunction of. equipment previously evaluated will not be increased.

(2) create the probability for an accident or malfunction of a different type than previously evaluated since no change in plant operations or to equipment or components is required. The changes revise the RCS specific activity reporting requirements from a special report to an annual report in accordance with Generic Letter 85-19.

(3) involve ~a significant reduction in the margin of_ safety since the change in reporting requirements are administrative in nature and do not affect the safe operation of the plant. The technical specification limits remain unchanged and the bases have been revised to reflect the change in Action statements as recommended by the NRC.

These changes do 'not ~ involve any physical changes to plant safety related systems, components or structures, will not increase the likelihood of a malfanction of safety related equipment, increase the consequences of an accident previously analyzed, nor create the possibility of a malfunction different than previously evaluated.

Therefore, based on the above, it is proposed to characterize the change as involving a no significant hazards consideration.

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