ML18025B869
| ML18025B869 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/17/1982 |
| From: | Vassallo D Office of Nuclear Reactor Regulation |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8209010262 | |
| Download: ML18025B869 (28) | |
Text
(
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Docket File I&E-1 NRC PDR S. Norris ORB¹2 Rdg OELD ACRS-10 Gray NSIC LPDR R. Clark D. Eisenhut Docket Nos.
50-259 50-260 50-296 AUG 1 7 )g~
tir. Hugh G. Parris tlanager of Power Tennessee Valley Authority
, '00A Chestnut Street, Tower II
- 'hattanooga, Tennessee 37401
Dear Hr. Parris:
Subject:
Radiological Effluent Technical Specifications Re:
Brooms Ferry Nuclear Plant, Units 1, 2 and 3
Reference is made to our letter of February 24, 1982 and to subsequent discussions with your staff on the above subject.
He have completed our review of the Browns Ferry Radiological Effluent Technical Specifications (RETS).
Our review also covered the Offsite Dose Calculation tlanual (ODCN) and the Process Control Program (PCP).
Our comments and questions on your submittals are enclosed.
Domenic B. Vassallo, Chief Operating Reactors Branch ¹2 Division of Licensing
Enclosure:
1 To resolve these
- comments, we have a arranged to meet with your staff at the Brooms Ferry site on August 18 and 19, 1982.
The NRC and NRC contractor personnel
>iho will be present are as follows:
Richard J. Clark, NRR/NRC Charles A. Hillis, NRR/NRC Daniel H. montgomery, Region II/NRC William Serrano, EG&G Idaho, Inc.
A. H. Akers, EG&G, Idaho, Inc.
We look forward to meeting with you and are confident the meeting will result in a mutually acceptable RETS and ODCH for the Browns Ferry Nuclear PlantI.
Sincerely,
/
Qtiginal signed bf D, B. Vass".Po 8209010262 820817 PDR ADOCK 05000259 P
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Mr. Hugh G. Parris CC:
H. S. Sanger, Jr., Esquire General Counsel Tennessee Valley Authority 400 Commerce Avenue E 11B 33 C
Knoxville, Tennessee 37902 Mr. Ron Rogers Tennessee Valley Authority
'400 Chestnut'Street, Tower II Chattanooga, Tennessee 37401 Mr. H.
N. Culver 249A HBD 400 Commerce Avenue Tennessee Valley Authority Knoxville, Tennessee 37902 Resident Inspector U. S. Nuclear Regulatory Commission Route 2, Box 311
'thens, Alabama 35611 I
Athens.Public Library South and Forrest
- Athens, Alabama 35611 Mr. John F.
Cox Tennessee Valley Authority
. M9-D 207C 400 Commerce Avenue Knoxville, Tennessee 37902 George Jones Tennessee Valley Authority
'P. 0.
Box 2000
- Decatur, Alabama*
35602 James P. O'Rei 1ly Regional Administrator, Region II U.S. Nuclear. Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303.
RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)
REVIEW I.
~Pur ose The purpose of this document is to provide licensees with examples (i.e.,
prior to the in-plant review) of areas where further clarification is needed in the review of their RETS submittal and Off-Site Dose Calculation manual (ODCM).
Some of the areas addressed are such that full compliance with the model RETS is necessary, however, in many cases a justified alternative that meets the intent will be considered in compliance.
No.
NUREG-0473 Browns Ferr Comments The following definitions were not included in the RETS submittal:
1 1.10 2
1.19 3
1.33 4
1.34 5
1.32 6
Table 1.2 7
3.3.7.11 8 '.3.7.11 9
3.3.7.11 BB Table 1.1 3.8.A.7 3.8.A.7 3.8 4.8 Channel Check
'ose Equivalent I-131 Gaseous Radwaste Treatment System Ventilation Exhaust Treatment System The definition of the Offsite Dose Calculation Hanual should specify the inclusion of methods for calculating the alarm/trip setpoints.
The frequency "P" (completed priov to each release) could be inc'luded in the submittal.
This tech spec addresses only the liquid radwaste gross activity monitor.
Are there other activity monitors that should be included in the proposal7 The LCO does not state that the.
alarm/trip setpoints shall be set in accordance with the ODCN.
The Applicability "at all times" should be included in the submittal.
" 10 Action a An action comparable to action "a" of the model RETS was not included.
No.
NUREG-0473 11 Action c 12 4.3.7.11 Browns Ferr 4.8 Comments The model RETS does not require that Specifications 3.0.'3 and 3.0.4 of the Standard Tech Specs be applied to the majority of the specifications.
The plant should be aware of this exemption in their proposal.
There is not a surveillance. statement comparable to that of the model RETS although the surveillance is being performed.
13 Table 3.3.7.11-1 3.8.A.7.a Action 110 The submittal should require that the analysis done when the automatic alarm and termi nation of release instrumentation is inoperable should be in accordance with Table 4.8.A, and that two (qualified) station personnel independently verify the release rate calculations as well as the discharge line yalving.
14 15 Action 110 16 Action 113 17 Item 2a 3.8.A.7.a 3.8.A.7.a 3.8.A.7.a 3.5.8
'(p.
153A)
The second sentence should be completed by being changed to read "provided that,"
or something similar, before "two independent samples. "
The phrase "only during the succeeding 14 days"'may be removed.
r Suspension of releases should be given as an alternative to the alternate monitoring system.
An action statement should be included requiring the flow rate to be estimated at least each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during releases with less than the minimum number of flow rate channels operable.
The Service Mater Effluent Line radiation monitor is not addressed except when the RHR system pressure is greater than the service water pressure.
Is it possible for radioactive effluents to be released to the environment at other times via the service water effluent linel 18 Action 112 3.5.8 The service water grab samples should state they will7be analyzed at an LLD of at least 10 pCi/ml.
0
No.
NUREG-0473 19 Item 2b 20 Item 3b 21 Item 4a 22 Item 5 Browns Ferr Comments Monitors for the Component Cooling Mater System Effluent Line are not addressed in the submittal.
Can radioactive effluents be released to the environment via this pathway without being monitored?
The submittal does not address the following items:
Flow Rate Monitor for the Discharge Canal Radioactivity Recorder for the Liquid Radwaste Effluent Line Tank Level Indicating Devices (if undiked exterior tanks exist) 23 Table 4.3.7.11-1 4.8.A 4.8.A.3 Is the Instrument Check of the submittal the same as the Channel Check of the model RETS7 24 Item la'5 Item 3a 26 Item 3a 4.8.A.3 4.8.A.7-4.8.A.7 The submittal does not require a source check of the Liquid Radwaste Effluent Line Monitor prior to each release.
The submittal should require a daily channel check for the Fl ow Rate Measurement Device on the Liquid Radwaste Effluent Line.
A quarterly channel functional test is required for the liquid radwaste flow rate measurement device.
27 wow 4.8.A.7 The submittal states the accuracy shall be checked quarterly.
Does accuracy mean the same as a calibration7 Accuracy was not defined in the definitions.
28 Item 3a 4.8.A.7 The calibration is required every 18 months whereas the accuracy is checked quarterly.
No.
NUREG-0473 Browns Ferr Comments Surveillance for the following items are required if they are added to the Radioactive Liquid Effluent flonitoring Instrumentation Requirements 29 Item 2b 30 Item 3b 31 Item 4a 32 Item 5 33 Notation 1
4.8.A.3 Component Cooling Water System Effluent Line monitor Discharge Canal flow rate device Liquid Radwaste Effluent Line radio-activity recorders Tank Level Indicating Devices for external tanks Does the functional test only demonstrate
'ontrol room annunciati'on or does it also include the required automatic termination of release7 34 Notation 1
35 36 37 ftem 2a 4.8.A.3 4.8.A.4 4.8.A.4 4.5.5 The functional test should also demonstrate'larm and auto termination of release when there is a circuit failure or when the instrument is not set in operate mode.
Is this a functional check of the auto isolation or does it only check the valve opening and closing operation7 Is tank selection "values" a typo~
The submittal should require a monthly source check of the RHR service water radiation monitors.
38 Notation 2
4.5.5 The channel functional test should demonstrate control room annunciation when the four conditions exist that are'described in the model RETS.
The following notations were not included in the submittal.
39 Notation 3
40 Notation 4 41 Notation 5
42 Notation 6
43 3.3.7.12 3.2.K.1 Channel Calibration using known sources Channel check Recorders with alarm/trip functions Tanks requiring level indicators It is not stated that the alarm/trip setpoints will be set in accordance with the ODCM.
No.
NUREG-0473 44 3.3.7.12 Action a 45 Tabl e 3.3.7.12-1 1 ~
46 Table 3.3.7.12-1 2 ~
47 Table 3.3.7.12-1 3 ~
48 49 Table 3.3.7.12-1 50 Table 3.3.7.12-1 5
.51 Table 3.3.7.12-1 6., 7., 9.
52 Table 3.3.7.12-1 10.
53 Table 3.3.7.12-1 notation 54 122, 123, 127 Br owns Ferr Table 3.2.K Table 3.2.K Table 3.2.K Table 3.2.K 3.
Table 3.2.K notation A,B,D Comments There is no requir'ement to either declare the channel inoperable or to suspend releases if the alarm/trip setpoints are less conservatively set than required by the ODCM.
The main condenser off-gas treatment system monitor is not listed.
@drogen and o>magen monitoring instru-mentation has not been addressed.
I Why are the iodine and particulate sampling instrumentation not identified as monitoring channels for all release
. points7 What is indicated by the parameter statements No effluent flow rate instrumentation is listed at any release point.
Why are effluent monitors on the turbine building operable only during releases7 This is normally a continuous release point.
See **footnote.
Are the monitored release points the only effluent release points for all plant systems (e.g., fuel storage, gland
- seal, and mechanical vacuum pump)7 No monitoring instrumentation for the condenser air ejector system prior to delay 'is listed and the action corresponding to Action 121 of the model RETS.
Action statements listed in the model should be addressed when the specific monitor is included in the submittal, i.e., Actions 121, 124, 125 and 126.
No time period for using temporary equipment is now -specified and Action B should reference Table 4.8.B.
55 123 Four hour grab samples are more conserva-tive than required by the model.
No.
IIII EG-0413 Comments 56 Table 4.3.7.12-1 Table 4.2.K 4
57 Table 4.3.7.12-1
- Table 4.2.K Surveillance requirements should be addres'sed for all monitoring instru-mentation to be included in Table 3.2.K (i.e., effluent monitors, etc.)
Footnotes 1, 2, and 3 of the model on channel calibration and channel functional test are not listed in the. table.
All elements of the functional test have not been included (i.e., circuit failure and automatic isolation).
Footnotes 1
and 2 of the submittal are not used in the table.
58 Item 4e 59 3.11.1.1 Item ld 3.8 The channel calibration and functional test for the stack sampler flow meter are listed as not applicable.
The applicability statement restricts the tech spec to controlled releases only.
The word "controlled" should be removed from the applicability
'tatement.
60 4.11.1.1.1 4.11.1.1.2 4.8.A.2 The results of the sampling must be analyzed in, accordance with the ODCM.
61 62 63 Table 4;ll-l Table 4.8.A The footnote 4 in the table should be relocated, i.e., "principal gamma emitters
"..'he analysis of dissolved and entrained gases are for gamma emitters only.
Are there continuous releases that should be addressed in this table, e.g., service water effluents7
'64'ootnote a
65 Footnote b
66 Footnote c
Footnote e
Footnote 2
A footnote defining the "a priori LLD" and equation was not included.
The footnote should be expanded*to state the sample is representative of the liquids released.
If there are continuous releases with continuous sampling then these'footnotes are required.
No.
NUREG-0473 67 Footnote d
68 Footnote f 69 3.11.1.2 70 4.11.1.2 71 3.11.1.3 72 4.11.1.3.1 73
. 3.11.1.4 Browns Ferr Footnote 1
Footnote 4
3.8.A.3 4.8.A.5 3.8.A.5 4.8.A.6 Comments The footnote should state the batch should be isolated and thoroughly mixed prior to sampling.
The model RETS requires that all peaks measurable and identifiable shall be reported.
Footnote 4 limits the reporting to those that account for approximately 95$ of total activity.
Is drinking water taken from the receiving water within three miles downstream of the plant dischargel The reference to the ODCM was omitted.
Is the Figure 4.8.A.l or 4.8.17 The reference to the ODCM was omitted.
The tech spec limiting curie contents in liquid storage tanks was'ot addressed.
Of particular concern are temporary-tanks.
74 3.11.2.1b 75 3.8.B.l.b 4.8.B b The tech spec could be reworded to state "The dose rate limit for I-131, H-3 and particulates with greater'than eight day half lives shall be...."
There appears to be a word(s) missing in this specification.
76 77
'.11.2.1.1 4.11.2.1.2 4.11.2.1.2 4.8.B1,2 4.8.8 2
The surveillance statements address activity and not dose rates.
The reference to the ODCM was omitted.
Table 4.11-2 78 Item A Table 4.8.B Are there waste gas storage tanks that should be included in this tablel 79 Item B
80, Item C
81 Item D
Item A Item B
Item C
The sample should be obtained prior to the purge.
The submittal does not state the grab'amples are obtained monthly.
I-133 may be removed from the table.
No.
NUREG-0473 82 Item D
Br owns Ferr Item C
Comments The principal gamma emitters for the weekly particulate sample must include I-131.
83 Item D
Item C
A noble gas monitor with the corres-ponding LLD of 1
x 10 yCi/ml was not included.
84 Footnote a
85 Footnote b
The footnote describing the "a priori" LLD" and equation was not included.
This footnote identifying the additional analysis following power changes was not included.
. 86 Footnote d
87 Footnote e
This footnote identifying the additional
.sample changeout and analysis following power changes was not included.
This footnote identifying the 7 day
'ampling for H-3 analysis whenever spent fuel is in the spent fuel pool was not included.
88 Footnote f 89 90 3;11.2.2 Footnote 2
3.8.B.3 This footnote was not included.
C.
, This footnote requires quantification.
Is the "*" footnote redundant'or
- example, "per unit" is in 3.8.8.3 and the "*" is in 3.8.B.3a and b.
91 4.11.2.2 92 3.11.2.3 93 4.11.2.3 94 3.11.2.4.
4.8.B.3 3.8.8.5a,b 4.8.B.4 3.8.8.7 The reference to the ODCH was omitted.
The words "to any organ" were 'omitted; The reference to the ODCH was omitted.
Why isn' the discharge of the SJAE routed through the charcoal adsorbers at all times the SJAE are operable instead of only above 50$ power when projected doses exceed certain'efined limits?
95 3.8.D Should the monitors for the mechanical vacuum pump be included in the gaseous instrument Table 3.2.K7
No.
NUREG-0473 96 3.11.2.5 97 3.11.2.6 3.11.2.6.A 98 3.11.2. 7 Browns Ferr Comments A tech spec addressing the Ventilation Exhaust Treatment System was not included.
A tech spec addressing the explosive gas mixtures was not included.
A tech spec addressing the gross radioactivity rate from the SJAE was not included..
99 3.11.2.8 100 4.11.3.2 Do the Browns Ferry plants have Mark I or Mark II containments7 If so a tech spec is required to state that venting or purging of the drywell shall be through the Standby Gas Treatment System.
Th'ese surveillance requirements were not included in the submittal.
101 4.11.4 102 3.12.1 103 3.12.1 4.12.1 1 04 wow
'.8.C 3.0 3.0 3.1 The reference to the ODCM was omitted.
The current radiological environmental monitoring program is listed in the'ODCM rather than the technical specifications as required by the model.
No applicability statement is listed that requires the monitoring program to be done "at all times" and the surveillance statement was not included.
Technical specifications 6.7.1;d and 6.7.2.c on reporting requirements were not included in the submittal.
105 3.12.1 a,b,c The equivalent of model action requirements 3.12.l.a, b,
and c are not listed in the submittal, and related section 5.6.3 of the submittal'has been deleted.
106 Table 3.12-1 1 ~
107 Table 3.1-1 Airborne Does the statement "continuous sampler operation with sample collection weekly" apply to all particulate air samplers.
It is not specified that the gross beta analysis will -be performed
> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the filter change.
No.
108 109 NUREG-0473 Browns Ferr Airborne Airborne Comments Is the requirement for a gamma scan if 3
the gross beta concentration is 1.0 pCi/m greater than the control stations as conservative as the model requirement.
The sampling requirements for fallout, rain water and soil are not requirements of the model.
110 Tabl e 3.12-1 2 ~
111 Table 3.12-1 3.
Table 3.1-1 Table 3.1-1 The model requires 40 sample locations.
Composite sampl'es should be stated as having aliquots collected at less than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> intervals.
112 Table 3.1-1 Sr analysis is listed in several sections but is not required by the model.
113 Item 3.c 114 Tabl e 3.12-1 4b Materborne Table 3.1-1 Fish No requirement for biweekly samples and I-131 analysis is listed for drinking water samples.
1-3 areas are indicated for the collection of milk samples.
This should be clarified.
Is the total fish analyzed or edible portions only and the frequency require-ments are not clear2,
. 116 117 4c 118 Table 3.12-2 119 'able 4.12-1 120 Food.
Food Table 3.2-1 How many sample locations are there for, food products.
I-131 analysis for broad leaf vegetation is not specified.
No table listing the reporting levels for radionuclide concentratio'ns in environmental samples is listed.
An asterisk marked footnote is listed for section A., should this not reference gamma analysis methods.
Is the method with the lowest LLD (i.e.,
NaI(Tl) or Ge(Li)) used for specific analyses.
10
No..
NUREG-0473 Browns Ferr Comments 121 122 The LLD for I in drinking water and milk is listed in the model as 1
pCi/liter.
Fe is missing from the table.
The copy was difficult to read and a
comparison should be made to Table 4.12-1 of the model RETS.
123 124 Tabl e 4.12-1:
Notation a
Table 3,2-1 notation The model requires fish samples to be listed wet weight rather than dry.
What is the'onversion factor for wet, weight?
The LLD definition should include that the LLD's are "a priori."
A minus sign is missing in the exponent in Note 1
fo'r Table 4.2-5.
Also "y" is used in the Equation for Table 3.2-1 however "Y" is defined.
125 Notation b
126 Notation c 127 3.12.2 128 3.12.3 LLD's for drinking water are not listed.
No statement requires other than the listed radionuclides to be reported when measurable.
A land use census specification was not included.
An interlaboratory comparison specifi-cation was not included.
129 Bases.
130 6.5.1 6.5.2
.131 6.8 132 6.9.1.7 5.6.2.b Some elements of the bases statements, although unenforceable, are not included.
Adequate information is not present in the submittal to define the functions of the unit review group and the company nuclear review and audit group as listed in the model.
Specific elements of the procedures section for the PCP;- the ODCM, and the quality assurance program are not listed.
No statement is made requiring a map of sample locations, and results of the Inter-Lab Comparison program.
No.
133 NUREG-0473 Br owns Ferr 5.6.3 Comments The purpose of this section which has
'een deleted is unclear.
- 134, 6.9.1.9 135 6.9.1.12 136 6.9.1.13f 137 6-10.2 138 '.13.2.C 139 6.14 140 6.15 141 6.7.3.a 6.7.2.b.6 5.7 6.3. E 6.12 6.7.3 The requirements for the semiannual report listed in the second, third,=fifth and sixth paragraphs below'section 6.9.1.9 in the model have not been addressed-Also items d, e, and f of paragraph four were not included.
Exceeding the'urie limits in the liquid or gaseous storage tanks requires prompt notification reporting.
This reporting requirement is now a special report for environmental samples instead 'of a 30-day written report.
It is unclear that "the inplant portion" of the records that shall be retained meets the requirements of the model RETS.
No requirement is listed for documenta-tion of the fact that changes to the PCP have been reviewed by the URG.
Changes to the'ODCM are to be included in the semiannual report rather than the monthly.
The reporting requirements for major changes to the radioactive waste treatment systems are not included.
The model RETS was modified to eliminate the requirements of an LER and to limit the doses such that subsequent releases are in compliance with the LCO statements.
12
l
BROWNS FERRY ODCM REVIEH No.
Comment 1
Equation 'l.l page 4 has a term, exp(-X ), what is the function of this terms 1
uJ Equation 1.1a page 4 has a term h, how is this term determinedl Equation l.la page 5 the term c is defined by an equation C = 3(1.5 -
M /u)d.
Can C be multiplied by d and also how is atmospheric pressure accounted for in this equation7 Equation 1.1a page 4, another equation which may serve the same function for h is as follows.
ah
= I.1.5 '+ 2.68 x 10 p
(
T
) dj u
s where hh
= plume rise above release point V = velocity of exhaust plume m/s d = stack inside diameter m
u = average wind speed m/s p = atmospheric pressure.mb T
= temperature of stack gas 'K s
T
= ambient temperature
'K 5
Equation 1.5 page 9'and 1.7 on page 10 needs to be clarified.
6 Equation 1.8"page 12 can-be removed.
7 'quation 1.26 page 21 dose to !-133 does not need to be determined.
8 Equation 1.27 page 21 can be removed.
This pathway analysis is not
, required unless it is significant.
Equation 1.26 page 21.
Why aren't you using the results from equations 1.7 and,l.l0 for determining the dose from milk or equation 1.117 13
No.
Comment 10 12=
13 15 16 Page 16 terms for gi and OF
- should be unit of yCi not Ci.
Page 21 terms for f131 and OF131 should be unit of pCi not Ci.
Why aren't the Grass-Cow-Neat and Yegetation pathways addreseed in the submittal for gaseous dose calculationsl Table 1.7 page 38 should any other internal dose factors be shown.
Where are, the references for figures 1.1 and 1.22 A block diagram figure showing the liquid and gaseous release systems
.should.be included.
In Equation:2.12 and 2.14 page 53 why is the dilution factor (d) usedl Why are the units of rem and mrem included in equations 2.11 and 2.13 on page 53'?
18
. Is the receiving water used for agricultural practices2 19 The following is a list of items for inclusion that has been requested by ETSB.
1.
Reference to the FSAR for all instruments for which setpoints are determi'ned.
2.
Methods and equipment used for determining dilution.
30 The location and distance to the nearest residence,
- cow, goat, meat animal, and garden.
20 4.
A figure showing the gaseous effluent restricted area.
Section 2.2.1 oh page 50 states the setpoint methodology is contained in Technical Instruction 45.
Shouldn't this be included in the ODCN which is Technical Instruction 47.
21 Section 2.3.2.2 on page 53.
Should the i in the first sentence be an
~ I,'7 1'
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