ML13333A427

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Responds to Wp Gammill 790917 Request for Method Demonstrating Compliance w/40CFR190 Requirements Re Evaluation of Radiological Effluents.Evaluation Performed on Semiannual Basis
ML13333A427
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 11/01/1979
From: Baskin K
Southern California Edison Co
To: Ziemann D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 7911070533
Download: ML13333A427 (2)


Text

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROV.E AVENUE ROSEMEAD, CALIFORNIA 91770 K. P. BASKIN November 1, 1979 TELEPHONE

MANAGER, GENERATION ENGINEERING 213-572-1401 Director of Nuclear Reactor Regulation Attention: D. L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:

Subject:

Docket No. 50-206 40CFR190 San Onofre Nuclear Generating Station, Unit 1 Mr. William P. Gammill's letter dated September 17, 1979 requested that we commit to a method for demonstrating compliance with 40CFR190 requirements which become effective on December 1, 1979.

This commitment is required in light of the fact that the radiological effluent technical specifications submitted to the NRC by letter dated September 12, 1979 may not be in effect by December 1, 1979.

The specification in NUREG-0472, Revision 2, designed to comply with the provisions of 40CFR190 (3/4.11.4, Total Dose), requires that a Special Report be prepared and submitted to the Commission whenever the calculated doses due to plant radioactive effluents exceed twice the 10CFR50 Appendix I doses.

It goes on to state that the dose commitment due to other uranium fuel cycle sources is negligible with the exception of those fuel cycle facilities within a five mile radius of the plant.

The NUS report entitled, "Final Report on the Study of Liquid Radwaste System Backfitting Requirements for San Onofre Nuclear Generating Station Unit 1,"

dated July 22, 1975 was provided to the NRC as Enclosure 1 to a letter dated June 7, 1976.

This report documents an engineering study of the liquid radwaste system at San Onofre Unit 1 by NUS. This study concluded that with regard to radioactive liquid effluents the design objectives of 10CFR50 Appendix I were met during the period of 1972 through 1974 and should continue to be met. A report entitled, "Evaluation of Radioactive Gaseous Effluents from the San Onofre Nuclear Generating Station Unit 1 for the Years 1973, 1974 and 1975," dated September 18, 1976, was provided to the NRC by letter. dated October 7, 1976.

This evaluation concludes that no changes in current gas release practices are warranted relative to 10CFR50 Appendix I objectives.

Based on these two submittals the doses due to radioactive effluents from San Onofre Unit 1 have been and should continue to be within the Appendix I guidelines.

Mr. D. L. Ziemann

-2 We have compared the radioactive effluents released from San Onofre Unit 1 from 1976 through September, 1979 with the 1973, 1974 and 1975 releases which were addressed in the two reports. It was determined that the recent releases were less than or equivalent to the releases addressed by the reports with doses less than the 10CFR50 Appendix I guidelines. This indicates that the radioactive effluents from San Onofre Unit 1 are still within the Appendix I guidelines.

Based on the two reports provided to the NRC and our review of the more recent releases it is concluded that San Onofre will continue to operate within the 10CFR50 Appendix I guidelines. San Onofre's continued operation within the Appendix I guidelines should assure its compliance with the requirements of 40CFR190 as outlined in the NRC's specification 3/4.11.4 in NUREG-0472, Revision 2. In the future and until the radiological effluent technical specifications for San Onofre Unit 1 have been approved by the NRC we will continue to evaluate the radioactive effluents from San Onofre Unit 1 on a semiannual basis to ensure they are less than or equivalent to previous releases. If it is determined that the radioactive effluents exceed the previous releases and the doses due to these radioactive effluents exceed the Appendix I guidelines, a special report in accordance with that requested by Specification 3/4.11.4 in NUREG-0472, Revision 2, will be submitted to the NRC.

If you have any questions regarding this matter, please let me know.

Very truly yours,