ML19256E509

Forwards Proposed Changes to Ets,Allowing More Realistic Calculation of Dose Rates at Site Boundary.Fee & Affidavit Encl

ML19256E509
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/31/1979
From:	Cavanaugh W ARKANSAS POWER & LIGHT CO.
To:	Reid R Office of Nuclear Reactor Regulation
Shared Package
ML19256E510	List: ML19256E509 ML19256E513
References
1-109-28, NUDOCS 7911070551
Download: ML19256E509 (4)

Text

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s ARV.ANSAS POWER S LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK ARKANSAS 72203 (501)371-4422 WILLIAM CAVANAUGH lil October 31, 1979 Vice President Generation & Construction

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1-109-28 2-109-23 Director of Nuclear Reactor Regulation ATTN: Mr. R. W. Reid, Chief Operating Reactor Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 205c5

Subject:

Arkansas Nuclear One-Units 1& 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Technical Specification Change Request (File: 1511.1 & 2-1511.1)

GentIemen:

Attached for your review are proposed changes to the Arkansas Nuclear One - Units 1& 2 (ANO-1&2) Envi ronmen t a l Te chni c a l Specifications. These changes wil l al low mo re reali s t ic cal-culations of dose rates at the site boundary resulting from the release of gaseous wastes in the f o rm o f nobl e gases and other radioactive isotopes, except I-131 and particulate radioisotopes wi th hal f-lives greater than eight days. The bases for the changes are as follows:

Dose rates at the site boundary resulting frcm the release of gaseous wastes in the form of noble gases and other radio-active isotopes, except I-131 and part icula te radioisotopes wi th hal f-lives greater than eight days, are presen tly cal-culated using a dispersion factor (X/Q) which is based upon a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> model of worst case accident conditions which are not exceeded more than five percent of the time, with calms excluded. While this dispersion factor is justified for limiting the release rate over a one hour period, we feel that the factor is impra c t i c al and unduly restrictive for limiting the quarterly release rate. As the quarterly re-lease rate is actually dependent on annual site boundary dose rate objectives we feel that a dispersion factor based on annual average meteorological conditions is appropriate. The margin of safey to the health and saf ety of the public is 9

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1-109-28 2-109-23 Mr. R. W. Reid Oc t ober 31, 1979 still quite large as the annual site boundary dose rate objectives are only two percent of allowable dose rate to the public per 10 CFR 20, and in order to receive this two per-cent (10 mrem) an individual would have to be at the site boundary in the prevailing wind direction for the full year.

The use of an annual average dispersion factor concurs with what we presen tly believe to be the NRC position for off-site dose calculations. This understanding stems from our dis-cussions with the staff concerning the Off-Site Dose Calcu-la tion Manual required to complement 10 CFR 50, Appendix I Teshnical Specifications.

Further, Arkansas Power and Light Company (AP&L) requests that this proposed change be processed and reviewed in an expedited manner for the following reasons:

ANO+1 shutdown on October 19, 1979 to implement modifications committed to in our response to the Commission Order issued to us as a result of the TMI-2 event. However, we have not, to date, been able to ent3r the Reactor Building (RB) to per-form the necessary work dre to high radiation levels inside.

ANO+1 presently has high RB radiation levels due to a recent increase in failed fuel from 0.01% to 0.10%, and the subse-quent increased activity of the Reactor Coolant Sy s t en .

Reactor Coolant Pump seal leakage problems have released this activity into the RB atmosphere. Due to unplanned releases during this quarter, purging of the RB will not be viable until after November 5, 1979, wi th our present release rate limits. Purging prior to then would place us uncomfortably close to our quarterly release rate reporting limit, and purges prior to planned shutdowns before the end of the year would probably put us over this limit. Those shutdowns planned prior to the end of the year are to implement "Les-sons Learned" short t e nn requ i r ene n t s .

Personnel could be dispatched into the RB without purging to begin work immedi a tel y. However, the occupational dose due to immercion in the inert gases is presently estimated at 100 man-ren. We do not believe that exposing personnel to 100 additional nan-rem is in keeping with the ALARA concept as purging would deliver an estimated dose of only 1.25 mrem to an individual at the site boundary even using the accident dispersion factor. Wi th the mo re reali s t ic annual average dispersion factor the dose at the boundary would be estimated at less than 0. 2 5 mr em. This application of the ALARA con-cept coupled with'the daily loss of approximately $400,000 10^7 77 L JJn

1-109-28 2-109-23 Mr. R. W. Reid October 31, 1979 for power replacement suggests . hat human and public interest would be served by your expedient review and approval of this fechnical Specification change request.

Pursuant to the requirement of 10 CFR Part 170.22, we have determined that this request involves a single environmental issue with a duplicate for a second unit and requires a remittance o f $4400. A check for that amount is enclosed.

Very truly yours,

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Wi l l i am Cavan/ augh, I- I WC / ERG /cw Attachments 7 -

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STATE OF ARKANSAS )

) SS COUNTY OF PULASKI )

William Cavanaugh III, being duly sworn, states that he is Vice President, Generation & Construction, for Arkansas Power & Light Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this Supplementary Information; that he has reviewed or caused to have reviewed all of the statements contained in such infonnation, and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, infonna-tion and belief.

AWilliam lY a Cavanatgh III m.

SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the County and State above named, this 3/ day of  ?[u/NL/1979.

,- t4bt Oth' lan A b Notary Pdblic / '

My Commission Expires:

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