ML19250B968
| ML19250B968 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 10/31/1979 |
| From: | Moody D YANKEE ATOMIC ELECTRIC CO. |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| WYR-79-129, NUDOCS 7911060335 | |
| Download: ML19250B968 (3) | |
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Telephone 617 366-90ll rwx fiO 390-0739 YANKEE ATOMIC El.ECTRIC COMPANY urR,,.12, 7f&
20 Turnpike Road Westborough, Massachusetts C1.581
- Yauxus October 31, 1979 B.3.2.1 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Office of Euclear Reactor Regulatics Mr. Denni<, L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) USNRC letter to All Power Reactor Licensees, dated September 17, 1979.
(c) YAEC letter to USNRC dated April 9, 1979 (WYR 79-46)
Yankee Rowe Offsice Dose Calculation Manual (d) Federal Register, Vol. 42, No. 9, January 23, 1977; Pg. 2858
Dear Sir:
Subject:
Implementation of 40 CFR Part 190 As requested in your letter of September 17 (reference b), we are hereby mclosing interim criteria which will be used to demonstrate conformance with t tose provisions of the EPA Uranium Fuel Cycle Standard (40 CFR Part 190),
which become effective December 1, 1979. These int 2 rim criteria (Attachment A) shall be followed until such time as fomal radiological effluent technical specifications (RETS) become part of our operating license. These interim provisions shall not constitute limiting conditions of operation for the plant.
Our commitment for demonstrating compliance with 40 CFR Part 190, as detailed in Attachment A, follows the guidance given in NUREG-0133, chapter 3.8, and the provisions of Specification 3.11.4 of NUREG-0472, revision 2.
However, we take exception to the wording of the NRC proposed Specification 3.11.4 which implies that each individual licensee is directly responsible and accountable for releases from portions of the uranium fuel cycle beyond his own facility. We do not believe it necessary for each individual power plant licensee to be burdened, either directly or by implication, with the possibility of assesement of dose contributions from uranium fuel cycle facilities far removed from his own, and which he has neither any direct knowledge of, or any operational control over. TF is conclusion is based on EPA's stand intent concerning the implementation of the 40 CFR Part 190 standards. The EPA has determined that in the vast majority of situations, the sum of all rearonably postulable contributions from sources beyond 10 C
miles of a particular site will be small compi red to these standards and (9(,
shoLid be ignored in assessing compliance. The EPA has stated that,
%k 791106033S'
United States Nuclear Regulatory Commission October 31, 1979 Page 2 B,3.2.1 "it would not be reasonable to attempt to incorporate into compliance assessment doses which are small fractions of the uncertainties associated with the determination of doses from the primary source of exposure" (Reference d). The EPA has also determined as part of the promulgation of 40 C7R Part 190 standards that, except under highly improbable circumstances, confomance to the criteria of Appendix I to 10 CFR Part 50 should provide reasonable assurance of compliance with the standards for up to five reactor units at one site.
Since Yankee Rowe is a single reactor site, and since there are no other uranium fuel cycle facilities in the vicinity of the plant, it is concluded, based on EPA determinations, that che only dose commitments which need to be considered in Yankee Rowe's case are those resulting from on site (station) sources.
Should you have any questions regarding this subject, niease feel free to contact Mr. Mark Strum of our Radiological Engineering Group.
Very truly yours, c
Donald E. Moody Manager of Operations MS/smh 1272 323
Attachment A Total Dose (40 CFR Part 190)
A.
The dose or dose commitment to any real individual from all station sources shall be limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which shall be limited to less than or equal to 7! mrem) over 12 consecutive months (beginning December 1, 1979).
B.
With the calculated dose from the release of radioactive materials in liquid or gaseous ef fluents from the site exceeding any of the following criteria:
1.
3.0 mrem to the total body or 10.0 mrem to any organ during any calendar quarter due to liquid effluents released from the site; 2.
6.0 mrem to the total body a 20 mrem to any organ during any calendar year due to liquid effluents released from the site; 3.
10.0 mrad air dose fo. gamma radiation or 20 mrad for beta radiation during any c lendar quarter due to noble gases released in gaseous effluents to unrestricted areas; 4.
20 mrad air dose for gamma radiation and 40 mrad for beta radiation during any calendar year due to noble gases released in gaseous ef fluents to unrestricted area; 5.
15 mrem to any organ during a calendar quarter due to radioiodines and radioactive materials in particulate form, and radionuclides (other than noble gases) with half-lives greater than 8 days in gaseous effluents released to unrestricted areas; 6.
30 mrem to any organ during a calendar year due to radioiodine and radioactive materials in particulate form, and radionuclides (other than noble gases) with half-lives greater than 8 days in gaseous effluents released *o unrestricted areas; prepare and submit a special report to the Commission and limit the subsequent releases such that the dose or dose commitment to any real individual from all station sources is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This special report shall include an analysis which denonstrates that radiation exposures to any real individual from all station sour.1s, including all effluent pathways and direct radiation, are less than the 40 CFR Part 190 Standard. Otherwise, obtain a variance from the Commission to permit releases which exceed 40 CFR Part 190 Standard.
C.
Cumulative dose contributions from liquid and gaseous effluents shall be determined at least once per month in accordance with the Offsite Dose Calculation Manual (reference C).
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