ML19250C217
| ML19250C217 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/15/1979 |
| From: | Vissing G Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911230027 | |
| Download: ML19250C217 (9) | |
Text
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November 15, 1979 Docket No. 50-313 and 50-368 LICENSEE: ArkansasPower&LightCompany(AP&L)
FACILITY: Arkansas Nuclear One, Units 1 and 2 (ANO-1&2)
SUBJECT:
SUMMARY
OF MEETING OF OCTOBER 23, 1979, IN BETHESDA, MARYLAND, REGARDING RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)
Introduction By letter dated March 9,1979, and May 10, 1979, AP&L submitted proposed RETS for ANO-1 and 2 respectively. By letter dated July 9,1979, AP&L submitted the Off-site Dove Calculation Manual (ODCM) for ANO-1&2, Revision A to the ODCM was submitted by letter dated October 22, 1979.
As a result of our review of the RETS and the ODCM, we developed positions which were provided AP&L (Enclosure 1) to form a basis-for our discussions with AP&L. The purpose of this meeting was to discuss with AP&L our positions and those changes necessary to make their RETS and ODCM acceptable to the staff. provides a list of attendees.
Discussion The initial discussion related to the staffs positions for the inclusion of requirements of 40 CFR Part 190 into the RETS and inclusion of Technical Specifications for Solid Radioactive Waste into the RETS. With regard to 40 CFR 190, this is an EPA requirement. However, NRC has been delegated to implement the requirement. For this reason, it must be included in the Technical Specifications. As a pratical measure, because there are no other nuclear facilities near ANO-1&2, the dose commitment to an individual would be from ANO-l&2 only. With regard to the Solid Radioactive Waste Technical Specifications, there is a history of incidents involving the receipt of unacceptable solid waste at burial sites. The authorities of those states which have burial sites have expressed concern many times in the past. The licensee was infomed that we believe a Technical Specification on Solid Waste will minimize the frequency of unacceptable waste delivered to the burial sites and assure the state authorities that the final solid waste product will be from a controlled process. Therefore, it is our position that RETS will contain a Technical Specification on Solid Radioactive -
Waste, and it will include the Solid Waste Process Control Program (SWPCP).
The licensee was encouraged to submit the SWPCP. Following is a discussion of the changes to the RETS for ANO-2 necessary to make them acceptable to the staff.
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7 9112 3 o OM P
1.
Specifict.cion for liouid and gaseous monitoring at all times The requirements that the licensee proposed in Tables 3.3-12, 3.3-13, 4.2-12 and 4.3-13 provide that monitoring is only recuired when ever releases were being made. Our position is that monitoring would be applicable at all times for liquid and gaseous effluent. The AP&L position was that some systems would be off when not releasing effluent and therefore the monitor ~ would be off. Our position is that the monitor should be " operable" at all times, i.e. it could be turned off but it should be operable if turned on_ at any time.
2.
Monitor for the regenerative waste crocessinc system The staff's position is that Tables 3.3-13/4.3-13 should provide for monitors for the regenerative waste process system.
3.
Monitor for the service water systems The staff's position is that Tables 3.3-13/4.3-13 should provide for monitors for the service water system. AP&L was concerned that the limiting condition of operation (LCO) in the event of the monitor was inoperable would mean that the service water system would need to be shut down. Such a condition during any mode of operation is unacceptable.
We committed to provide AP&L guidance on an acceptable LCO.
4.
Other tanks applicable in Tables 3.3-13/4.3-13 We were concerned that the condensate storage tank and other tanks were not identified for monitoring. The licensee indicated that there were no other tanks applicable in Tables 3.3-13/4.3-13.
5.
LCO's reouired in the event monitors are inocerable Many LC0's in the the event of inoperable equipment do not have a time limit. We requested the licensee to put a time limit of 30 days on such action statements. AP&L was concerned that in the event that the inoperable equipment could not possibly be returned to service within 30 days, the LCO would imply that the plant would need to shut down. We indicated that, if such an event occurred, the licensee could request relief through a request for a Technical Specification change.
It was recognized that this may not be a proper LCO and there-fore we would provide the licensee guidance on what is acceptable.
6.
Containment nurae monitoring system The staff's position was that the action statement concerning inoperable monitoring system should be to suspend purging. ANO-2 is not permitted to purge in modes 1, 2, 3, or 4.
The licensee will review their system
.for conformance to the s"ff's position.
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. 7.
Monitoring for explosive gaseous mixtures Our position ~ was that the monitor which should be added is the monitor of the gas which would be added to an existing gas to provide the explosive mixture.
For instance, if tanks collect hydrogenated gases, then oxygen should be monitored and have the Technical Specification limits.
8.
Analysis of liquid waste Our position is that P-32 and Fe-55 should be analyzed. The licensee believed this is too costly and time consuming. The staff considers the position to be finn.
9.
Turbine buildino caseous samoling' AP&L coamitted to provide for sampling in the turbine building.
- 10. Dose Commitment to Individuals The staff's position is that dose comitments from 1.'iquid effluents and gaseous effluents should include an annual dose.
- 11. Radioactive Gaseous and Liauid Waste Systems The staff's position is that the system should be operable at all times, i.e. they will operate whenever turned on at any time. Also, the dose values should be those which are specified in NUREG-0472. The licensee indicated that the gaseous waste system was not operable but would be by the time the RETS are implemented.
- 12. Total curies TS in liouid holduo tank A total curies should be applicable to the liquid holdup tank.
- 13., 14., 15., TS for explosive mixtures, solid waste system, and 40 CFR 190 These subjects were discussed separately in 7 above and the initial discussion above respectively.
For the most part, the staff's comments in the particular sections of. ANO-2 RETS also applied to the applicable sections of the ANO-l RETS. We provided the licensee a copy of the RETS for ANO-1 TS which was in the fonnat of ANO-1 TS but with our narrative. We requested the licensee to use our narrative when revising the RETS for AN0-1.
The Offsite Dose Calcidation Manual (ODCM) was reviewed secarately. AP&L hand delivered Revision A of the ODCM dated October 22, 1979. We proviced the licensee guidance and the Branch Technical posi-ion on radiological monitoring.
1 3 8.5 i 4 ()
The RETS for ANO-1&2 us they relate to meteorology was discussed secarately and a list of concerns, Enclosure 3, was provided and discussed with the licensee.
Conclusion The licensee was requested to revise the proposed RETS and ODCM for ANO-1&2 consistant with our coments and discussions and resubmit the revised RETS and ODCM within 30 days.
/
/
Operating Reactors B,ct Manager G. S. Viss e
ranch #4 Division of Operating Reactori
Enclosures:
- 1. ~0 pen Items - ANO-1&2 Tech Specs 2.
List of attendees 3.
RETS Coments (Meteorology)
!30.5 1S0
Enclcsure 1 OPEN ITEMS - ANO-1 TECH SPECS 1.
For Tabl es 3. 5 e6-1, 3. 5. 7-1, 4. 27.1 -1, 4.27. 2-1, same cornent as ANO-2 comment #1.
2.
In Table 3.5.6-1 same comment as ANO-2 #3.
3.
In Table 3.5.6-1 same comment as ANO-2 #4.
4.
In Table 3.5.5-1, action B, same connent as ANO-1 #5. Also Table 3.5.7-1, action B and C, same comment.
5.
In Table 3'.5.7-1, same commen,t as ANO-2 #7.
6.
In Table 3.7.7-1, same comment as ANO-2 #6.
7.
In Table 3.5.7-1, indicate whether there are iodine and particulate samples in the vents - if not, indicate how you will determine level of release.
8.
In Specification 3.22.2, 3.23.2, and 3.23.4, same comment as ANO-2 #10.
9.
In Specification 3.22.3 and 3.23.5, same comment as ANO-2 #11.
- 10. Same comment as ANO-2 #12.
- 11. Same comment as ANO-2 #13.
- 12. Same comment as ANO-2 #14.
- 13. Same comment as ANO-2 #15.
14.
Same comment as ANO-2 #9.
15.
In Table 4.27.1-1 and 4.27.2-1, indicate what the channel functional test will demonstrate and the channel calibration for ANO-l.
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OPEN ITEMS - ANO-2 TECH SPECS 1.
The specification for liquid and gaseous monitoring should be applicable "At All Times" in Tables 3.3-12, 3.3-13, 4.3-12, 4.3-13.
2.
In Table 3.3-13/4.3-13, add the monitor for the regenerative waste processing system.
3.
In Table 3.3-13/4.3-13, add the monitor for the service water system.
4.
In Table 3.3-13/4.3-13, are there other tanks, such as the condensate storage tank, which should be in the table? If not, why not?
5.
On page 3-56, action items 18 and 20 should have maximum -imes of 30 days.
Also on page 3-19, action items 26, 27 and 28 should have maximum time.s of 30 days.
6.
In Table 3.3-12, the action for containment purge should ce to suspend purging.
7.
In Table 3.3-12/4.3.-12, add the monitors for explosive gas mixtures.
8.
In Table 4.11-1, add P-32/Fe-55 sampling.
9.
What sample provisions are there for turbine building sampling, i.e., is it grab sampling or continuous composite samples.
10.
In specifications 3.11.1.2, 3.11.2.2 and 3.11.2.3, add the annual dose limits.
11.
In specifications 3.11.1.3 and 3.11.2.4, indicate that the systems will be OPERASLE and use the dose values indicated in NUREG-0472.
12.
Add the specification for total curies in liquid holdup tank.
13.
Add the specification for explosive gas mixtures.
14.
Add the specification for solid waste system.
- 15. Add the specification for 40 CFR 190.
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OCTOBER 23,1979 l1EETING i.!!0-1/2 APDENDIX I ATTENDANCE LIST NRC AP&L Guy S. Vissing David G. Ma; dis W. C. Burke Mark A. Smith P. C. Wagner Steve Petzel D. J. Vito Basil Baker D. S. Brinkman Gary Fiser L. Brown J. Osloond F. Cardile F. Congel*
Jim Cortis*+
- Part Time Attendance
+
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ARKANSAS - RETS COMMENTS (METEOR 0'_0SY:
Unit 1 Technical Soecs (Memo from W. Cavanaugh, I*: tc R. W. Reid, dated March 9, 1979)
Section 4.25.2 Dose, Noble Gases (p. Il0ff)
Why are the " Bases" different than for " Dose, *odine & Particulates,"
- p. 110gg? What calculation methods will be used in the ODCM (e.g.,
will they be consistent with Regulatory Guides 1.109 & l.111 or something else)? Will doses be based on historical reteorology or something else?
Unit 2 Technical Specs (Memo from W. Cavanaugh, III to J. Stolz, dated May 10,1979)
Section 3/4.11.2.3 Dose, Radiciodines (p. B 3/411-4)
Will doses be based on historical meteoralogy or something elje?
Units 1 & 2 Technical Specs In Section 6.9, " Semiannual Radioactive Effluent Release Report" a statement should be inserted about (1) providing suraary of hourly meteorological data collected during the previous year and (2) determining gaseous pathway doses (for purposes of the radioactive effluent release report submitted at the end of the year) based on -
meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents.
(See attached "Adminis-trative Controls" page).
If you agree to (2), then the tables of short term release [(X/q)h,e(X/q)y, enclosure]afe,and(D/q)y, (D/q)
Tables 4.ll-6e not submitted.. Tables through Table 4.ll-6h in 4.ll-6a through Table 4.11-6l,in the enclosu(re] are stilY, submitted for long term release [(X/Q)
(X/Q)y, (D/Q, and (D/Q)
~ Tables in the ODCM if you decide you want to submit tables of values rather than one maximum X/Q and D/Q value as you've currently done in the ODCM.
ODCM Based on information provided to NRC for the Appendix I evaluation, the turbine building releases have caps or diffusers and we therefore consider them as ground level releases. Therefore, ground level release X/Q and D/Q values should be provided in the ODCM.
If tables of X/Q and D/ Q values are used in the ODCM, in the text part of the ODCM, reference the appropriate table, rather than citing a specific X/Q or D/Q value.
(You do not have to use tables if you don't want to - you can stick with maximum effsite X/Q and D/Q values.)
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.j MEETING SUtV%RY DISTRIBUTION ORB #4
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Mr. William Cavanaugh, III
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Vice President, Generation and Construction Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Docket File R. Reid NRC PDR V. Noonan L PDR P. Check ORB #4 Rdg G. Lainas NRR Rdg G. Knighton H. Denton Project Manager E. G. Case OELD OI&E(3)
D. Eisenhut R. Ingram R. Voliner R. Fraley, ACRS (16)
W. Russell Program Support Branch B. Grimes TER1t**
T.-J. Carter J. R. Buchanan A. Schwencer Meeting Summary File D. Ziemann NRC Participants T. Ippolito G. Vissing W. Gammill W. C. Burke L. Shao P. C. Wagner J. Miller D. J. Vito D. S. Brinkman L. Brown J. Osloond F. Cardile F. Congel J. Cortis 1385 1bS