ML17244A384

Summarizes 790110 Meeting Re Radiological Effluent Tech Specs.Util Will Submit Draft Tech Specs within Two Weeks & Final Version by 790215

ML17244A384
Person / Time
Site:	Ginna
Issue date:	02/07/1979
From:	James Shea, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 7903050495
Download: ML17244A384 (17)

Text

Docket Ho. 50-244 LICENSEE:

Rochester Gas 8 Electric Corporation FACILITY:

R. E. Ginna Nuclear Power Plant

SUBJECT:

SUt1NARY OF MEETING HELD OH JANUARY 10, 1979 In response to HRC letter dated July ll and November 15,

1978, representatives of Rochester Gas and Electric Corporation (RGBE) and the Nuclear Regulatory Commission (HRC) met in Bethesda,

Maryland, on January 10, 1979, to discuss Radiological Effluent Technical Specifications.

list of attendees is attached.

The NRC letters requested the licensee to incorporate the requirements of 10 CFR Part 50, Appendix I into the R. E. Ginna Technical Specifications.

Prior to the meeting RGEE provided specific Standard Technical Specification subjects for discussion at the meeting.

The items identified by RGBE and meeting comments follow.

STS-1.31 "Ginna solidification equipment will ensure no free standing water, not a free standing solid."

STS-1.33, 1.34 "Me have defined this as the equipment assumed in the Appendix I analyses."

RG8E has a 2 ga'lion/minute evaporator which runs approximate'1y one-fourth of the time.

For laundry waste they use a reverse osmosis unit, except during shutdown when the flow would be two great'or this unit and then it is discharged to the lake.

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WZC PORhf 518 (9-76) NRCLK 0240 Dewatered resins are to be covered by this port'ion of the STS.

RG8E should submit its proposal as an alternate to this STS and describe costs and schedules involved if required to meet the STS.

The batch sampling requirement, one sample from every ten batches, means that there is sampling prior to mixing with cement - a sample of the raw feed material to test for pH, etc.

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t1EETQEJG SUfNARY fEB 7

1979 Waste treatment systems should be all systems as described in Appendix I submittal and include all those which were given credit in the analyses.

Lab filters although they may be used, can be ignored fn the Appendix I analyses.

Oescrfbed systems don't have to be operated all the time ff not needed to stay below the dose objective, but described systems have to be operable and tested per tech spec conditions.

b RGSE should explain in the ODCH their rationale for use of the systems.

New portable systems would be considered as being covered under 10 CFR 50.59 and should be described in the semi-annual report.

These systems must be evaluated, and may require surveillance requirments.

Changes to systems are to be submftted with the monthly operating report.

STS T3.3-11 NDlowdown monitor not requfred if blowdown fs being II bl I I

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being released, may continue indefinitely if activity is less than 1 x 10"7 and grab samples taken.

We only have one oxygen monitor that cycles between tanks."

The blowdown monitor is not required to be operable if not discharging to the environs.

RGBE's cover gas, which is hydrogen enriched, is connected to the gas decay tank.

The system was not designed to withstand explosions and has only one oxygen monitor which cycles between the various sampling points.

The current tech spec, which allows for oxygen monitors to be out and sampling to be conducted every four hours, was designed for a system which could take an explosion.

RGBE wants one oxygen monitor, and ff this monitor is inoperable, a provision for taking a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sample.

RGCE may be required to install another oxygen monitor, or at least sample every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

STS T3.3-12 NHhy are samples taken every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if they were only analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?N The samples taken iifthfn a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period must be analyzed within the next 24 houis.

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tiEETItlG SUt1tNRY FEB 7 $7S STS 3.11.1.2 "The action item requires reporting in 30 days if either the quarter or annual limits are exceeded, but 6.9.1.F requires reporting only if the annual limit is exceeded.

Explain the discrepancy7N

.If the levels of the environmental samples exceed the annual limits on a projected basis for the year, there is a potential"problem and this should be reported.

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II STS 3.11.2.1 NWe v(ould rather have limits for Part 20 on release

rates, rather than dose rates.

It is easier to implement.

We'e provided that unplanned releases may be averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Keep the'dose limit as an LCO for releases, but in the ODCN calculate setpoints based on historical meteorology and most restrictive isotopes; if setpoints are exceeded the individual isotopes can be used to determine whether or not an LCO has been exceeded.

In mal;ing the determination historical meteorology must be used even if actual meteorology shows dose limitwas not exceeded.

Although RGEE has an instaneous iodine monitor which allows seeing some short term spikes, if a cartridge is pdlled, they are not to be penalized by having to average over the shorter sampling period.

The release rate. should be averaged over the required period of sampling.

That is if the specified sampling time is ? days, they can average over

? days, if it drops to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> because of increasing release

rates, they should average over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is the shortest sampling period required by -the present tech specs for iodine.

A STS 3.11.2.5 "Since there are no other fuel cycle facilities any where near Ginna, we propose that if the plant alone meets 40 CFR

190, we have met it for the entire fuel cycle."

t/ew guidance will be issued by the NRC to cover this matter and therefore this matter may be deferred until that time.

STS 3.12.1 and 3.12.2 "We put these in Section 4 since the spec scat on doesn t seem to have a real limit for'operations."

This is not acceptable.

A positive statement is still needed in-Section 3 in the Tech Specs.

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STS 3.12.3 "This fs a gualfty Assurance,Ifunctfon which doesn' h

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check through IAE split samples.

Are there any f,nter lab programs now approved by the t<RC?N EPA presently has an acceptable. inter lab comparison program.

The gA analyses required of.the licensee should only be for those nuclfdes and samples reqgfred by the Technical Specifications.

I STS T4.3-11 "We'e listed several

'channel checks as only prior to release since the releases are only occasional or of relatively short II te rmr I

These checks should be on'a daily basis if the systems or releases are continued in accordance with the STS.

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STS 4:11.1.1.1 and 4.11.1.1.2 "These and sfmf'lar specs just seem to restate the LCOs and don t add anything.

He'd prefer to delete these."

The intention of these specs waC explained.

STS 3.11:2.2 "While STS address normal

gases, we have in the past limited gross activftp except airborne iodine and particulates with half-lifes.greater than 8 days.'- 'Any reactfon7N p

RGBE equates gross activities wfth noble gases.

The continuous gas monitors are not sensitive enough to see releases.

A 2.5 liter.

weekly sample is used to Idetermfne releases.

'h The monitor must be sensitive, enough to see 10-6uCf/cc or 10 mrads afr dose, that fs, within Appendix I limitations.

RG8E indicated that they will use the STS fn this area..

d STS 3.11.2.2 and 3.11.2.3 NHe prefer to have the Appendix I values f n tech specs and add fn C-14, etc., f n the ODCH rather than have some strange number in the tech specs."

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lying The calculated C-'l4 doses for RGBE will be less than 0.1 millirem according to NRC.

Therefore, the total dose limit will not be reduced by the C-14 number.

RGSE should have some general state-ment in the 00Cf1. It >>as noted that there is nothing in the STS related to direct radiation.

RGSE also asked about analysis of P-32 and Fe-55.

Although'hese nuclides are not in the "Gale Code,"

this was pointed out as a limIitation in the present model versus the actua'l situation.

This may be changed later during a subsequent tech spec change.

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.STS T4.11-2 NWe have deleted continuous air sample for gas decay tanks and air ejector."

'GBE has a monitor in the stack which provides the same control function as would a continuous sample of the gas decay tank.

NRR wants an air ejector monitor to cover this release path during any steam generator tube leaks.

RG8E will evaluate.

"We have dropped Gas Decay Tank (GDT) tritium since studies have shown this to be a trivial contribution."

RGBE wants to get rid of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling in Table 4.11.2 for tritium because they'e run their refueling pool cold and they do not see much evaporation.

In addition, they do'not run (not their practice) with any primary to secondary leakage.,

Their secondary is running approximately 10-8 microcuries/cc.

RGBE takes this sample of gas by cooling it, and they haven' seen any tritium in these samples.

On this'asis, RG8E may be able to justify deletion of this requirement for GDT tritium.

"lie have dropped requirments for extra samples after startup and

shutdown, since these don't particularly affect our releases that will be'ccurring at these times."

RG8E has a continuous iodine monitor.

This may be O.K. if RG8E modifies the T'ec'h Specs to indicate that they will change the

'iodine cartridge whey the continuous iodine monitor rises to a predesignated setpoint.

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"We have dropped air ejector tritium if secondary activity is less than 10

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RGBE should come in with the proposal to this effect, and it will be evaluated.

STS 3.11.2.7, "The NRC's 1969 SER assumed instaneous release of 30,0QO Curies from a gaseous decay tank and got a dose of 3 rem whole body.

Is it possible to draw sufficient information from this to justify no specification.

'Fur ther, since 1

GDT is always lined up.for sma'll

gas, addition, it seems that lone sample/24 Pours is excessive.

Perhaps du~ing bur ping.of VCT it's justified."

Although RGSE has no Curie,- tech spec limit on the GDT now, it will

,probably be necessary in the future.

Sampling less frequently than every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> may be justifiable.

STS F3.12-1 NWould like to have extra location 'shown so that we could'ave one or two out of service and.not have to report it."

= NRC general.ly expects the licensee to maintain adequate spare parts and to.have maintenance progi am such that samplers would not be out more than two consecutive periods.

"!le have never had a problem with dust loading, so we left that out."

This is acceptable.

"Our composite samples are daily samples."

A composite sample will probably be required for lake water at the Ontario Water intake prior to processing.

Drinking water might also be taken here or at another one of the licensee's specified locations.

E "We propose milk samples every fifteen days from tune through October."

RGSE should come in with a proposal, but it likely will,not be approved.

The STS may be required.

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w FEB 7 )979 STS 6.9.1.10 "lie would like to submit the ODCtl changes in the semi-annual effluent release report, since we want the operating report to be a summary of operations which can be quickly and briefly prepared.""

RG8E can propose this, but it'will probably not be approved without a

. strong justification.

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, This requirement is now in STS, but not in Ginna's and viill not'be required for Ginna.

The administrative portion of these tech specs was included in the STS package just for completeness.

f STS 6.5.1.6.J,"It took us several years to get rid of this;,It' undefined.

Is a'n unplanned release a case where valve packing leaks slightly7" ld NRR wants to review all unplanned

releases, not just those which have to be reported.

NRR,will have to provide some definition as to the level of unplanned release meant here.

STS 6.16.2 "Me have deleted NRC initiated changes.

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STS 6.16.3 "This says a major change is a major change.

Is there a

ttt "'t" Refer to Appendix I submittal for comparisons.

HRR will provide some additional information here.

I RG8E will submit a draft of their proposed Technical Specifications for Radiological Effluents within two weeks and the company approved Technical Speci.fication by February 16, 1979.

+ Q.&~

J. Philip Stohr, Chief Environmental and Specia Projects Section Region I

Attachment:

James J.

Shea, Project Manager Operating Reactors Branch 82 Division of Operating Reactors orrlcc~

lNIRNAMCW DATE3N':

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/79 PIRC PORN 318 (9 76) NRCN 0240 JHf U,', OOVRRNMIENl' RINTINO ORRICCI I ~li l0$ l~ 9

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Mr. Leon D. White, Jr. FEB V 1979 CC Lex K. Larson, Esquire

LeBoeuf, Lamb, Leiby 8 MacRae 1757 N Street, N.

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Washington, D.

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20036 Hr. Michael Slade 1250 Crown Point Drive

Webster, New York 14580 Rochester Committee for Scientific Information Robert E. Lee, Ph.D.

. P. 0.

Box 5236 River Campus Station Rochester, New York 14627 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza

Albany, New York 12223 Director, Technical Development Programs State of New York'nergy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604 Mr. Leon D. White, Jr.

Vice President Electric and Steam Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649

LIST OF ATTENDEES B. Necredy R. ttatts E. L. DeHenett D. Fi1ion BRC L. Andrews L. Barrett J.

S. Bland M. Britz J. Co11ins R.

Emch H. M. Shanbaky.

Region I J.

P. Stohr, Region I J. J.

Shea.

6. H. Knighton DFFICC~

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