ML19210B007
| ML19210B007 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/28/1976 |
| From: | James Buchanan NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Ballard R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911010742 | |
| Download: ML19210B007 (8) | |
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Central File Minogue SD RDG Smith SD ALPHA Mattson D #e ESB RDG Roberts g ','.
ESB Subject Kastner Buchanan Ronald L. Ballard, Chairman Advisory Comittee on Standardized Environmental Technical Specifications (ACSETS)
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J. Kastner, Chief Environmental Standards Branch, SD C0tHENTS ON DRAFT ENVIRONMENTAL TECHNICAL SPECIFICATIONS FOR THREE MILE IS The attached connents on the draft Three Mile Island Technical Specifications were prepared before receipt of the Miriutes of the November 11.-1976 meeting. My only additional cocinant, which is prompted by these Minutes, is that I do not agree that the femat of Section 4, "Special Studies,"
should be the same as that for Section 3.
If the Section 3 format can i
be applied to a particular study, it can be included in Section 3.
I However, the Section 3 format is not suitable for laboratory studies, one-time field studies, etc. (see RG 4.8). Apparently, there needs to be more discussion of format for Sections 3, 4, and, possibly, for the i
l Section 5.8, "Special Requiriments."
[
J. Buchanan Environmental Standards Branch
' Office of Standards Development cc: See attached Distribution list j
Enclosure:
As stated
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JBuchanan JKastner IX 12/27/76
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DISTRIBUTION:
ADVISORY COMMITTEE ON STANDARDIZED ENVIRONMENTAL TECHNICAL SPECIFICATIONS M. Beebe, MIPC J. Buchanan, SD T. Cain, D0R L. Cohen, I&E R. Grill, SD M. Grotenhuis, D0R C. Haupt, DSE J. Mapes, OELD J. McGough, D0R F. Miraglia, DSE E. Verdery, D0R DSE TASK GROUP H. Berkson - Thermal C. Billups - Aquatic J. Lehr - !!ater Quality G. Gears - Terrestrial
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C0i*1ENTS ON NOVEMBER 8,1976 DRAFT OF THREE MILE ISLAND ENVIR0tiMENTAL TECHNICAL SPECIFICATIONS 1.0 Definitions The definitions of time periods (annually, quarterly, semi-monthly, weekly) are both very unusual and ambiguous We recomend deletion of these definitions and, instead, following the suggestion made at the meeting to include in the tech. specs. a variance in specified minimum elapsed time periods of X% (25%?).
The definition given for " composite sample" is actually a definition for a
" proportional composite sample."
In general, a comp 6 site sample is any sample made up of distinct parts.
The definition of " daily maximum concentration" is incorrect in stating that "... concentration means the... determination..."
Suggest revising to:
" Daily maximum concentration means the maximum concentration recorded for any calendar day."
This definition of " Functional Test" should be deleted.
It is taken frcm Standard Appendix A tech. specs. but it conflicts with the definition of the saca term as used for radioactive effluent monitoring.
(See attached definition from the December 3 draft of the Radioactive Effluent Standard Tech. Specs.)
The definition of "Gama Scan (Gamma Spectroscopy)" should be deleted.
It is not needed in tech.' specs.
(The definition that it indicates onTy a qualitative analysis.) given is also misleading in The definition of " Grab Sample" should be changed to delete the too specific requirement of ".. collected in less than fifteen minutes."
The definition of " Indicator Station" seems to imply that the perception of ad'lerse environmental effects is expected at such a location.
Suggest:
"An indicator station is a sample location at which it may be possible to detect environmental effects of station operation."
The definition of " Instrument Check" should be deleted as unnecessary. The definition given is actually a definition of a visual check of an instrument.
In response to public comments the RG 4.8 review group has agreed that requirements for reporting " Unusual or Important events" of this type should not be in the environmental tech. specs.
Darinitions relating to radioactive effluents (? 2.4 of R.G. 4.8) have been sraested by J. Boegli for inclusion in R.G. 4.8, however, he now agrees that inclusion of definitions in the standard tech. specs, would be more appropriate th a including them in the Guide. (See definitions attached.)
Th2 addition of definitions for " precision" and " accuracy" was suggested in the meeting.
The follcwing definitions are taken from Analytical Chemistry crl are suggested for use in the tech. specs. if it is decided that definitions o? these terms are needed in the tech. specs.
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Accuracy _-normallyreferstothedifference1errororbias)betweenthe mean, f, of the set of results and the value X, which is accepted as the true or correct value for the quantity measured.
It is also used as the difference between an individual value X. and T.
The absolute accuracy _
of the mean is given by X
'X and of an ' ndividyal value by Xi - I.
The accuracy by 100 (X - X)/h.ean is given by (X - X)/f, and the p_ercentage relative accuracy _pf the m Precision - relates to the reproducibility of measurements within a set, that is, to the scatter or dispersion of a set about its central value.
2.0 Limiting Conditions for Operation 2.1 Thermal The specification and surveillance requirement do not correspond to one another.
Either the specification (s) should be rewritten to provide limits on inlet and discharge water temperatures and flow rate through the cooling towers in order to correspond to the draft surveillance requirement or the i
surveillance requirement should be rewritten to provide surveillance of the mode of operation of the station in order to correspond to the draft specification.
On p. 4, in line 2 of the Bases,is " endorses" an appropriate word?
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2.2~ Chemical
_.2.1 pH Delete "SU" after the pH unit: on pp 5 and 6 and add the word " inclusive."
In line 4 of the Surveillance requirement, add the words "and measurement" after the word " sampling."
' 2.2 Biocide The Draft Supplement to the FES and the EPA effluent limitation guidelines discuss " free available" and " total residual" chlorine, but the LC0 covers
" free residual" chlorine.
This is confusing.
Consistent terminology should be used in the FES and LCOs.
Presumably " free residual" in the LC0 has the same meaning as " free available" in the FES and in the EPA effluent limitations.
3.0 Environmental Surveillance It is our understanding that.he Comittee prefers the title " Environmental tbnitoring" (to avoid confusion with the " surveillance" requirements associated with LCOs) and the following format:
. Environmental Monitor..ig Requirement
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. Applicability
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. Cases We concur in this format fo: Jnvironmental Monitorin; 'lequirements.
'-.l.2b Terrestrial We question the basis (need) for erosion control inspection, transmission rights of way management, and aerial remote sensing as environmental monitoring program elements. We have referred to fWREG-0056 (July 76)(which is the draft supplement to the FES and which includes the FES as Appendix B) and, as indicated in the following comments on these program elements, are unable to verify statements concerning the FES which are made in the Bases sections for these program elements in the draft tech. specs.
.2.b(1) Erosion Control Inspection Specification of practices relating to erosion control as an environmental surveillance (monitoring) program element is inconsistent with R.G. 4.8 in which this type of activity is listed as an example of a "Special Requirement" (R.G. 4.8 5 5.8, p.12)
The requirement for field logs is a record-keeping rather than a reporting requirement.
~Ihe " Bases" refer to "the environmental assessments as defined in the Final Supplement FES-0L of 1976 (Section 6.5)"; however, section 6,5 of NUREG-0016 (p.6-2) merely indicates that during normal transmission line inspections, notations be made of any areas which may require reseeding and that a
-brief report of any such areas and confirmation of action to remedy the condition should accompany the annual report.
.2.b(3) Aerial Remote Sensing Why specify any particular minimum time period (5 years) for possible modification or deletion of this program element? Modification may be desirable earlier than this.
Commitments for NRC action (in " Surveillance Requirements" and " Reporting Requirements") are inappropriate in tech. specs.
" Bases" should refer to @ 6.5 of the draft supplement to the FES in which it is stated that "a low altitude true and false color aerial photography program should be implemented for correlation with the vegetation surveys."
4.0 Special Surveillance and Study Activities Ttie LC0 type of format used in this section is inappropriate for special surveillance and study activities and is inconsistent with RG 4.8.
1.1 hsidual Chlorine Surveillance Program Thecommentforj2.2.2concerningtheterm"freeresidual" chlorine applies to this section also.
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RADI0 ACTIVE EFFLUEllT STANDARD TECH!!ICAL SPECIFICATI0!1S Section 2.4 FOR BOILItJG WATER REACTORS 12/03/76 1564 107
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STANDARD TECHNICAL SPECIFICATIONS SECTION 2._4 0**0
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" a-Definitions The definitions given below are of a restricted nature and apply to terms used in these Technical Specifications.
Action shall be those additional requirements specified as corol-lary statements to each principle specification and shall be part of the ACTION:
specifications.
A batch release is the discharge of fluid wastes of a dis-BATCH RELEASE:
crete volume.
An instrument or device calibration shall be the adjustment, as necessary, of the output such that it responds with the necessary range CALIBRATION:
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and accuracy to known values of the parameter (s) which the including the sensor, indicator, controT feature, alarm and/or trip f sor or device monitors.
The calibration may be performed by and shall include the functional test.
any series of sequential, overlappilig or total circuit steps such that
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entire circuit is calibrated as specified.
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.of instrument accuracy and precision of calibration shall be recor e the plant records.
A continuous release _ is the discharge of fluid waste CONTINU0US RELEASE:
of a non-discrete volume, e.g., from a volume or system that has an input
. flow during the continuous release.
An effluent radiation monitor is an instrum EFFLUENT RADIATION ?10NITOR:
to provir continuous indication of the level of radioactive mate effluents to unrestricted areas.
automatic isolation or valve closure on the monitored effluent line prior ~
to exceeding a specification.
Implicit with the definition is the re-quirem9nt that flow control shall be provided by either an established minimum fiow switch or an actual rate sianal from a flow in and that an alarm device be provided locally and in the main control room to e'ur.ci te at the specified set point.
Free water is da,'ined as uncombined water riot bound by the FREE 's'ATER :ix following solidi'ication of radicactive wastes.
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A functio-il check shall be the injection of a simulated FUNCTIC;U CHECK:
sigm! ir. o a circuit at the arina.ry sensor to verify circuit behavicr Instrur it checks shall pernit observ aton of an es-du r-;,,, cL ery ation.
tab'isiN value other than c f alue observed when the instrumen Sensor checks si f_...
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s while disconnected from its normal circuit function and subjecting the sensor to the parameter (s) normally monitored.
Functional checks shall include alarm and/or trip functions but may be blocked from performing the ultimate specified function.
FUNCTIONAL TEST:
A functional test shall be a verification of operability by performing all specified functions using the parameter (s) which the instrument sensor or device monitors.
KNOWN RADI0 ACTIVE SOURCE:
A known radioactive source is a referenced cal-ibration source capable of reproducible geometry, emitting beta and gamma radiation with energies covering the range of the radiation monitor and containing one or more radionuclides normally mecsured by the radiation monitor.
All sources used for calibration shall be calibrated by a measure-ment system which is traceable to the National Bureau of Standards radiation measurement systems, and the plant records shall contain a copy of this information.
OPERABLE - OPERABILITY:
A system, subsystem, train, component, or device shall De operable or have operability when it is capable of perfornirg its specified function (s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, electric power, cooling or sea water, lubrication or other auxiliary equipment that are re-quired for the system, train, component or device to perform its function (s) are also performing their related support function (s).
PROCESS RADIATION MONITOR:
A process ra'diation monitor is an instrument to provice continuous indication of the level of radioactive materials in
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non-effluent lines or tanks.
Ul! RESTRICTED AREA:
An unrestricted area is any area, access to which is not control'. d by the licensee for purposes of protection of individuals from expostre to radiation and radioactive materials, and any area used for resi-dential purpose.
Control of such access requires the licensee to fulfill the obligations of 10 CFR Part 20.101, 20.102, 20.103, 20.202, 20.2C6 and 20.401, r.ot withstanding that for the purposes of 10 CFR Part 20.106, 50.3?
cnd 50.35, the boundaries are clearly defined as follows: (description of the site boundaries to be prcvided by the licensee).
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