ML18043B027

Forwards Draft Matl Re Radiological Effluent Tech Specs Submitted on 790115 & 0312,in Response to NRC 790808 Request.Addl Info to Be Submitted in mid-Nov 1979

ML18043B027
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	09/14/1979
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7909190297
Download: ML18043B027 (14)

Text

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General Offices: 212 West Michigan A11e11ue, Jacks~n. Michigan 49201 * (517) 788-0650 September 14, 1979 Director, Nuclear Reactor Regulation Att Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Coiilmission Washington, DC 20555 DOCKETS 50-155 AND 50-255 - LICENSES DPR-6 AND DPR BIG ROCK POINT AND PALISADES PLANTS - RESPONSE TO REQUEST FOR ADDED INFORMATION ON PROPOSED TECHNICAL SPECIFICATIONS CHANGES RELATED TO RADIOLOGIC.AL EFFLDENTS Transmitted herewith are dra~ materials relating to Big Rock. Point and Palisades Plants Radiological Effluent Technical Specifications submitted on January 15, 1979 and March 12, 1979, respectively.

The purpose of this letter is to respond with information requested by NRC letter dated August 8, 1979. Consumers Perwer Company has reviewed the re-quest and determined that only approximately five additional pages of Tech-nical Specifications are required for. each plant in response thereto.

Although it remains questionable that these Specifications are necessary for compliance with the statutes cited by the NRC, the added Specifications do not appear to provide an unacceptable burden to plant operations.

The draft materials enclosed with this letter have not undergone tecpnical review or necessary-approvals for inclusion into our Technical Specifications at this time. Appropriate reviews and approvals are expected to be obtained .

prior to submittal of the additional items in mid-November 1979. Both tech-nical and format changes are likely to occur in these materials prior to that time.

The following are item-by-item responses to the request for additional information (Enclosure 1) of your letter of August 8, 1979.

David F Hoffman, REGULATORY ooc.vrr llt I

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Assistant Nuclear Licensing Administrator CC JGKeppler

ENCLOSURE 1 Items 1) and 2) - Addition of specifications which address the maintenance, use, and corrective actions for inoperable radwaste treatment systems.

Response Specifications are being developed to address these aspects of radwaste system operation. Tentative wording for your preliminary review is attached.

Item 3) - Offsite Dose Calculation Manuals Response An Offsite Dose Calculation Manual for each site is under de-velopment. The manuals originally were scheduled for comple-tion by the end of December of 1979 under a contractual agree-ment with Gilbert/Commonwealth Associates. The timetable for compl¢tion of the manuals is being advanced to allow submittal by approximately November 15, 1979.

Each of the sections referred to in Enclosure 2 "General Contents of the Offsite Dose Calculation Manual" of your letter dated August 8, 1979, will be addressed in the ODCM's.

Item 4) - Addition of specifications to address solidification of wet solid radwaste, and submittal of a Process Control Program.

Response Process Control Programs for each plant should be available for submittal by approximately November 15, 1979. Tentative speci-fications for system operation are attached.

Item 5) - Provide figures that define site boundaries for liquid and gaseous effluents.

Response Figures are attached for your review.

Item 6) - Provide details on the site meteorological stations which support data used in determining dose impact to real individuals.

Response These details were provided in our original Appendix I submittals dated June 4, 1976, for each.plant. Summaries of this information, as appropriate, may be provided in the ODCM or associated proce-dures.

It~m 7) - Addproposed.~amplingand analysis programs to the .Technical Speci-fications for all site effluent release points having* potential for radioactive releases.

Response Tables 1, 2, 3 and 4 are provided to describe our sampling and analysis programs for the Palisades and Big Rock Point Plants.

Item 8) - The method to be used in calc1.llatihg alarm and trip set points on radioactive effluent monitoring systems in the ODCM.

Res~onse This item is intended to be addressed as Section 1 of each plant's ODCM. It is expected that the ODCM will be ready for NRC review by approximately November 15, 1979.

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A. Palisades Plant - Response to Items 1), 2) and 4)

EFFLUENT RELEASE SOLID RADIOACTIVE WASTE Applicability Whenever liquid radwaste requires solidification, dewatering or drying for offsite shipment in order that the limits of Specification 3.9.1 are not exceeded.

Objectives The solid radwaste system shall be capable of solidifying liquid rad-waste, dewatering the waste, or otherwise drying the waste to ensure meeting the requirements of 10CFR Part 20 and of 10CFR Part 71 prior to shipment of radioactive wastes from the site.

Snecificati6ns 3.9. Shipments of solid, dewatered or dried radioactive waste shall meet the requirements of 10CFR Part 20 and 10CFR Part 71. Ma-terials found defectively packaged shall not be shipped from site until defect is corrected.

3.9._ If the solid radwaste system is not capable of solidifying, dewatering or otherwise drying radwaste for more than 31 days when required to meet Specification 3.9,1, 10CFR Part 50.36a and 10CFR Part 71; prepare and submit to the Commission within 30 days, a Special Report, in lieu of any other report, which includes the following information:

1. Identification of equipment or*subsys~ems which prevent the solidification, dewatering or drying of radwaste.

2. Action(s) taken to restore the capability to solidify, de-water or dry the radwaste, or J. A description of alternative used for solidification, de-watering, drying and/or packaging of wastes, and

4. Summary description of a~tion(s) taken to prevent a re-currence.

3,9. The solid radioactive waste system shall be operated in accordance with the Process Control Program. Solidification shall be achieved by conversion of radioactive wastes from liquids to a. dry solid by removal of free water or conversion of liquids to a solid material. Free water shall be demonstrated absent from each container of solid waste shipped from site. Such demonstration shall be either by direct observation or by documentation of tests performed on similar, (but not necessarily radioactive) ,

materials.

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A. Palisades Plant - Response to Items* 1), 2) a.lid 4) (Continued) 3.9.~ The solid radwaste system shall be demonstrated to be capable of satisfactory solidification at least once per 92 days by either:

a. Operating the solid radwaste system at least once in the previous 92 days in accordance with the Process Control Program or

b. Verification of the existence of a valid contract for SOLIDI-FICATION to be performed by a contractor in accordance with a Process Control Program.

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A. falisades Plant - Response to Items 1) and 2)

EFFLUENT RELEASE LIQUID AND GASEOUS WASTE TREATMENT Specification

3. 9. The i.nstalled liquid and gaseous radwaste treatment systems shall be capable of processing radioactive materials, and shall be used to process the radioactive materials in liquid and gaseous wastes prior to their discharge when the projected release of effluents from the site (see Figure 1) wheri averaged over one calendar quarter would exceed Specifications 3.9.~ or 3.9.15.

3.9.~ If either radwaste system is not capable of processing effluents for two* consecutive calendar. quarters .and if radioactive effluent .

has been discharged from that system without processing in excess of 1/3 the above limits averaged over the two quarters, prepare and submit to the Commission within 30 days, Special Report, in lieu of any other report, which includes the following information:

1. Identification of cause for reduction in system processing capability.

2. Action(s) taken to restore processing capability.

3. Summary description of action(s) taken to prevent a recurrence.

3.9.~ Design basis annual quantities of radionuclides released in liquid and gaseous effluents shall be projected to the end of the current quarter and year, at least once per calendar quarter, in accordance with the Offsite Dose Calculation Manual.

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6 B. Big Rock Point Plant - Response to Items l} and 2}

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 3.5.1 STA'rION PROCESS EFFLUENTS (Continued}

EFFLUENT RELEASE H. Liquid and Gaseous Waste Treatment

1. The in'stalled liquid and gaseous radwaste treat-rnent systems shall be capable of processing radioactive materials, and shall be used to pro-cess the radioactive materials in liquid and

!* gaseous wastes prior to their discharge when the projected rel.e.ase of effluents from the

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• site *(see Figure 2.) when averaged. over one cal-endar quarter *would exceed Specifications 3.5.lA or 3.5.lB.

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2. .If either radwaste system is not capable of 2. Design basis annual quantities of radionuclides Vl JJii;ocessing effluents for two consecutive calen- released in liquid and gaseous effluents shall be dar quarters and if radioactive effluent has projected to the end of the current quarter and been discharged from that system without pro- year, at least once per calendar quarter, in cessing in excess of 1/3 the above limits accordance with the Offsite Dose Calaculation averaged over the tvo quarters, prepare and Manual.

submit to the Commission within 30 days, Spe-cial Report, in lieu of any other report, which includes the following information:

a. Identification of cause for reduction in system processing capability.

b. Action(s) taken to restore processing capability.

c. Summary description of action(s} taken to prevent a recurrence.

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• • • B. Big Rock Point Plant - Response to Items 1), 2) and 4)

LIMITING CONDITION -FOR OPERATION SURVEILLANCE REQUIREMENTS 3.5.1. " STATION PROCESS EFFLUENTS (Contd)

G. Solid Radioactive Waste G.

• Solid Radioactive Waste

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1. * .2hipments of solid, dewatered or dried 1. Materials will be inspected for compliance radioactive waste sh~ll meet the require- prior to shipment. Materials found defectively ments of 10CFR Part 20 and 10CFR Part 71. packaged shall not be shipped from site until defect is corrected.

2. The dry waste compactor and resin dewater-ing equipment shall be capable of packag-ing dry materials and dewatering resins, respectively, for shipment as necessary to maintain compliance with Specification 3.5.1.D.

3. If these systems are not capable of preparing 3; The dry waste compactor and resin dewatering shippable waste for more than 31 days when re- equipment shall be demonstrated capable of quired to meet Specification 3.5.1.D, 10CFR satisfactory operation within 92 days prior Part 50.36a and 10CFR Part 71, prepare and to use by either:

submit to the Commission within 30 days,. a Special Report, in lieu of any other report, a. Operation of the system at least once in which includes the following information: the previous 92 days, or

a. Identification of equipment causing the b. Verification of the existence of a valid problem. contract for such services.

b. Action(s) taken to restore satisfactory equipment performance, or

c. A description of alternative used for de-watering and/or packaging of wastes, and

d. Summary description of action(s) taken to prevent a recurrence.

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8 B. Big Rock Point Plant - Response to Items 1), 2) and 4) (Continued)

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS

4. Solid radioactive wastes shall be handled I~. In addition to specifying equipment operation in accordance with the Process Control requirements and handling criteria, the pro-Program. cedures which implement the Process Control Program shall require that free liquid be demonstrated absent from each container of solid :waste shipped from site. Such demon-stration shall be either by direct observa-tion or by documentation of tests performed on similar (but not necessarily radioactive) ,

materials.

TABLE 1 - BIG ROCK RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM ANALYSIS TYPE OF ACTIVITY APPROXIMATE LIMIT OF LIQUID _RELEASE TYPE SAMPLING FREQUENCY FREQUENCY ANALYSIS DETECTION {µCi/ml)

Principal Gamma Emitters 1 x 10-6 A. Radwaste Each Each Tanks (Batch) Batch Batch 6 I-131 1 x 10-M Composite H-3 1 x 10- 5

• 8 B. All Batch Releases Each Batch Q Composite Sr-89, Sr-90 5 x 10-6 Continuous Gross Gamma Mani tor Princinal Gamma Emitters 1 x 10-

c. Circulating Water Principal Gamma Emitters 5 x 10_.,

Discharge M 1 x 10-b CP Composite I-131 H-3 1 x 10->

n. Rad waste Discharge Continuous Gross Ganuna Monitor Gross Gamma 1 x 10- 5 Monitor during release E. Service Water Continuous Gross Gamma Monitor Gross Gamma 1 x 10-6 Discharge Monitor Q Quarterly W Weekly Draft 9/11/79 M - Monthly

TABLE 2 BIG ROCK RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM ANALYSIS GASEOUS RELEASE TYPE SAMPLING FREQUENCY FREQUENCY TYPE OF ACTIVITY ANALYSIS APPROXIMATE DETECTION LIMIT

.Continuous durini;! Noble Gas Noble Gases 4 A. Air Ejector 1 x 10- Ci/sec power operation Monitor Gross Gamma Off-Gas Hold-Up Line (Inlet) M Principal Gamma 4

during power Emitters including 1 x *10- µCi/cc Grab operation I-131

• Continuous B. Emergency Condenser dliring power Gross Gaseous Gamma 0.1 mr/hr Vent operation Gamma Emitters Monitor I

c. Stack Release Continuous Gross Gamma Gaseous Gamma 0.1 mCi/sec (includes continuous Monitor Emitters containment purge, vacuun pump and glanq seal con- Noble Gas Monitor Xe-133 0.1 mCi/sec denser, ai.r ejector, etc W Particulate Principal Gamma Emitters and Charcoal I-131 1 x 10 -10 µCi/cc Q

Composit Particu-lat.e Sample Sr-89, Sr-90 1 x 10 -10 µCi I cc Q - Quarterly W - Weekly Draft 9/11/79 M - Monthly

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TABLE 3 PALISADES PLANT RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM SAMPLING MINIMUM ANALYSIS TYPE OF ACTIVITIY APPROXIMATE LIMIT OF LIQUID RELEASE TYPE FREQUENCY FREQUENCY ANALYSIS . DETECTION (µCi/Mi) 1 x lo-6 A. Radwaste Batch ....E;acti Batch Each Batch Principal Ganuna Emitters Releases or I-131 l x 10-6 Occurrence H-3 1 x 10- 5 Q

Composite Sr-89, Sr-90 5 x 10- 8 Gross Gamma B. Sumps and Steam Continuous Monitor Gross Ganuna 1 x 10- 5 Gen Blowdown qr Grab Q

._ .. Composite Principal Gamma Emitters 1 x 10- 7

c. Service Water. Gross Gamma Monitor Continuous Monitor Gross Gamma . 1. x 10- 5 Gross Gamma 6 D. Circulating Water Monitor Gross Gamma 1 x 10-Discharge* Continuous 10_.,

(All liquid releases) 'sample w Principal Gamma Emitters 1 x Composite H-3 1 x 10- 5 Q

Composite Sr-89, Sr-90 5 x lo.:.. 8 E. Radwaste Discharge Continuous Gross Gamma

' Monitor During Discharge Monitor Gross Ganuna 1 x 10- 4 Q - Quarterly Draft 9-12-79 W - Weekly

TABLE 4 PALISADES RADIOACT1VE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM APPROXIMATE SAMPLING ANALYSIS TYPE OF LIMIT Of GASEOUS RELEASE TYPE FREQUENCY FREQUENCY AC'I'IVITY ANALYSIS DETECTION (µCi /m9..)

• Principal Gruruna Emitters 1 x 10- 4 I A. Waste Gas Decay Grab Each Tank Tanks Each Batch Containment Purge Grab Each Purge Principal Gamma Emitters 1 x 10-4 B. 6 Each Purge During Power I-131 (Charcoai) 1 x 10-During PowEr Operation Operation 1 x 10- 4

c. Condenser Offgas W' W during Principal Gamma Emitters Grab Power Operation I-'

1 x 10-10 I\)

D. Stack Release Continuous w I-131 (includes effluent Charcoal Sample*

from all the above ..

except offgas) w Principal

' Particulate Sample *Gamma Emitters 1 x 10-10 q

Composfte Parti-culate 1* *1 *:

Sr-89, Sr-90 1 x 10-ll Noble Gas Monitor Noble Gas Gross Gamma 5 x 10-5 e Xe-133 1 x 10- 5 Draft. 9/12/79 Q - Quarterly W - Weekly

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