ML17252A488
| ML17252A488 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/08/1974 |
| From: | Brian Lee Commonwealth Edison Co |
| To: | Case E US Atomic Energy Commission (AEC) |
| References | |
| Download: ML17252A488 (4) | |
Text
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.. Commonw.lh Edison One First Nati Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 Mr. Edson G. Case Acting Director Directorate of Licensing Off ice of Regulation U.S. Atomic Energy Conunission Washington, D.C.
20545 November *
Subject:
Dresden Station Units 2 and 3 Proposed Amendment to Facility Operating Licenses DPR-19 and DPR-25, Appendix A, AEC Dkts 50-237 and 50-249
Dear Mr. case:
Pursuant to Part 50.59 of 10CFR50, Commonwealth Edison Company requests a proposed amendment to DPR-19, Appendix A and DPR-25, Appendix A.
The purpose of this amendment is to delete from the Technical Specifications the requirement to conduct supplementary environmental monitoring whenever airborne radioactive effluents exceed one-third of the limits.
The amend-ment is indicated on the attached revised page 137 for both the Dresden Unit. 2 and Dresden Unit 3 Technical Specifications.
Attached is a safety evaluation for the proposed amendment.
The proposed amendment and safety evaluation *have r.eceived Onsite and Off site review and were approved as involving no unrevie~ed safety considerations.
Three (3) signed originals and 57 copies are submitted for your review and approval *
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SUBSCRIBED and SWORN to before. me this SJJ1; day of /U:_t.l~ /a\\ he \\J, 1974.
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.. (1.f{L(i ( £ ln. 1V.t-t.l; 1>~- od.l ~a,!J +/-0 J Notary Publ'.i.c
. Very trul~urs:
~C°:e. JJ Vice-President 11G21
- 1. 8 L!:\\rITJ:-\\G co~ OITIO~ FOR OPERATIO:'\\.
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Gl'nc.*rnl It is expected that release's of radioncth*e mnlc.*-
ri:tl in cfflu<:nts \\\\'ill hl' kt'pt at small fractions of llH' liniits sr***cifil*d in ~cction ~0. lOG of lOCFH J>a1*~ :rn. :\\l the :-.:1rnc time the licensee is pvrmitted tiw rtcxihil it.\\' of 01wi*ation, com-pati!Jlc- \\\\'ilh c.:*>11sidvrati*>11s of health :ind !:afet.\\*,
lo assure that th: p11bliC' is pro\\'irll'<l a dcpl'nd-ahl<* sourc1~ of p*n\\*c*1* ('\\'1*n under 1111usu:ll op~*rat ing-conditions \\\\'hil.'h may tl:mptH'at*ily result in rek:1sc*3 hiµ:h1*:: than such small it*ac-tii>ns. !Jut still \\\\'ithin ti:(* liniits sp('c.:ifi<:d in
~<:cti;in ~O. lOli 1Jf IOCFll Pan 20. It is C'xpcctcd that in using this 1>pc.*raliun:ll flexibility under unusual opc1*:1tin~; c:*mditions the licenscl' \\\\'ill c*xcrr his l>C'!':t..r1,11*ts to k1~cp le\\*cls or raclio-acti\\*c.* m:1tL*1*ial in cffluL"nts as lo\\\\' as practicable.
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-L 8 St:R\\'EfLLA'.:'\\CE HEQVlRE:\\JE~T Ope1*:1ting procedures shall be cle\\*cloped ancl usecl, and equipment which has bc<'n i.n~t:tllt*cJ to maint:tin l'lmtrul o\\*cr r:1diuac:ti\\'t* m:it(*riak
- in µ;:tsl'ous ancl liquid df:ul*nts p1*oducvd dur-in~ normal n*actor Of)L'l':ttilln~.
i11cludin1~
expl'cled opl'rational ucc111TencC's, shall lw m:1i11tainvcl and Usl'cl, Ill kcl'p l(*\\'t*ls or radio-ac:tin~ m:tlt*rial in dfluL*nts n*lc*:!s1*d to unrcslrit:ll'd arc:1s :is low as p!*:1cticabll~.
The cnv i t*o:111w!1 lal :non i tori n~!: prop::.J.. ULtd \\'<'n _
in Tab 1 e *I. ~. l ~ h:dl he condu<:ll'd. t A report shall be submittC'd to the Comm iss.ion at the end of each sLx-months' period of opcra:..
t!on spccif,ving-total quantities of raclioactivt*
matl'rial relcasl'd to t:n1*cstl'icted :1n*as in liquid and ~aseous effluents during the previous six months and sttch other information on releases as may be rl'quir<'d to l'Stimate exposun~s to the public rl'sulting-frnm efflu-ent releases. If quantities of radioacti\\'C matcrl:tl rclcasyd during tlw repol'tin;.; pc.*~lod arc unusual for norm:tl reactor o:wrations.
includin~ cxpectc*d operational occurrences, the report shall CO\\'L'r this specifically. On the bas is of such rep01*ts ~nrl any addition:i.l information the Commission ma\\' obtain fl'*>m the licens~c 01~ others. the Com.mission may from timL* to time rcquil'l' the lic:ensc*e to take such acti1in as the Commission deems appropt* iate.
137
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SAFJEY EVALUATION FOR REMOVAL OF SUPPLEMENTARY ENVIRONMENTAL MEASURING REQUIREMENTS FROM DRESDEN UNIT 2 AND 3 TECHNICAL SPECIFICATION SECTION 4.8.E
-The requirements of Unit 2 and 3 Technical Sp~cification Section 4.8.E ~ertaining to environmental monitoring have been reviewed by station personnel.
This section states 11The environmental monitoring program given in Table 4.8.1 shall be conducted.
Whenever th~ airborne effluents exceed 1/3 of the limits in Specification 3.8.A.2, measurements 2,3,5 and 6 of the Table 4.8.1. shall be performed at each farm adjacent to the site and at any cultivated or grazing land on-site. 11 It is our opinion that the routine environmental monitoring program conducted in accordance with Specification.
4.8.E adequately satisfy environmental concerns and that the supplemental measurements required by Specification 4.8.E are unnecessary.
T~.e routine radiological environmental monitoring program is an extensive program which was first implemented more than fifte~n years ago and involves sample collection and data analysis from more than forty sample locations both on-site and off-site.
Parameters monitored.in this program include direct radiation, airborne particulate, airborne 1-131, milk, grass, cattlefeed, precipitation, soi I, vegetables, water, fish, sediment, and other aquatic biota.
The extent of this routine monitoring program is illustrated by the fact that during 1973 a total of 3, 405 environmental measurements wis determined.. _Additionally, an extensive meterorological program is conducted in parallel with the environmental monitoring program.
. The supplemental measurements required by Specification4.8.E are unnecessary for several reasons.
For example, no specific time period for the airborne effluent re-lease is noted.
Thus, an instantaneous release requires the same additional monitoring, program as would a release that continued for weeks or months.
The specification re-quires supplemental monitoring at each farm adjacent to the site.
The peripheral areas of the sjte are primarily limited to industrial property and rivers.
The Specification also requires that supplemental monitoring wi 11 be conducted at any cultivated or graz-ing land on-site.
A special environmental study of station effluents was conducted in 1971 when higher than n6rmal releases to the atmosphere were experienced.
This study indicates that external gamma radiation exposure from noble gases and trace concentra-.
tion 6f I-131 in milk are the most probable dose pathways to unre,tricted areas.
The limited on-site grazing land is not used by dairy cows but by non-milk producing beef-cattle.
The limited on-site cultivated land has been used to produce silage crops for these beef cattle during non-grazing periods.
Thus an on-site iodine pathway to the thyroid through the grass-cow-receptor chain does not exist.
!'l.dditionally, the on-site grazing and cultivated land is located west of the station.
The supplemental monitor-ing required by the specification does not allow consideration of wind direction during airborne effluent releases.
A review of meteorological data indicates that the pre-dominant winds are from the south west.
Thus, the major fraction of airborne effluents would not drift over the limited on-site grazing and cultivated land.
Gross gamma back~
ground readings are routinely obtained to estimate the external radiation dose from cosmic and natural sources and from artificial radionuclides of station origin.
There is no technical basis for requiring special gamma background determinations which utilize standard ionization chambers and TLD measuring techniques for iodine and particulate releases within the limits imposed by the Technical Specifications.
These small con-tributors are overwhelmingly masked by cosmic and terrestrial 'background contributors.
The purpose of sampling and analyzing soil from vegetable farms, cattle feed, and grass from milk collection stations is to monitor possible fo9d chain dose pathways.
Since these.dose mechanisms do not exist either adjacent to or on _the site there is no basis for requiring these additional analyses.
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- Due to the above mentioned reasons 0e conclude that Section 4.8.E should be re-moved from the Unit 2 and Unit 3 Technical Specifications.