ML19256E621

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Forwards Info Describing Interim Compliance w/40CFR190,in Response to Encl NRC 790917 Request
ML19256E621
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 11/01/1979
From: Counsil W
CONNECTICUT YANKEE ATOMIC POWER CO.
To: Grimes B
Office of Nuclear Reactor Regulation
References
NUDOCS 7911080221
Download: ML19256E621 (6)


Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN, CO N N EC TIC U T P. O BOX 270 H ARTFORD. CONN ECTICUT 06101 TEL E seonsa 203 666-6911 November 1, 1979 Docket No. 50-213 Director of Nuclear Reactor Regulation Attn:

Mr. Brian K. Grimes, Assistant Director for Engineering and Projects U. S. Nuclear Regulatory Commission Washington, D. C.

20555

References:

(1)

W. G. Counsil letter to B. K. Grimes, dated January 18, 1979.

(2)

W. G. Counsil letter to B. K. Grimes, dated February 28, 1979.

(3) Meeting Notes, Docket No. 50-213, dated July 5, 1979.

(4)

W. G. Counsil letter to B. K. Grimes, dated August 1, 1979.

(5)

W. G. Counsil letter to B. K. Grimes, dated August 17, 1979.

(6)

W. P. Gammill netice to All Power Reactor Licensees, dated September 1', 1979.

Gentlemen:

Haddam Neck Plant Interim Compliance with 4M FR190 Pursuant to Reference (6), submitted herewith is Enclosure 1 which indicates the licensee's methei to be used to demonstrate compliance with 40CFR190.

We wish to note that dalays in receiving and processing these Technical Specifications are a result of the frequent revisions of NUREG-0472, thus, necessitating the repeated incorporation of corrections and revisions into draf ts of the Radiological Effluent Technical Specifications (RETS) and Off-site Dose Calculstion Manual (0DCM). This has also complicated and extended the review process.

However, we will continue to 1.ork as expeditiously as possible to reach our common goal, that of implementation of revised R: C ological Technical Specifica-tions and Offsite Dose Calculation Manual.

We would lik9 to re-emphasize the fact that it will take at least two months to revise operating procedures and install any additional equipment necessary to implement the final approved Radiological Effluent Technical Specifications 1293 318 7911080 5 S ! (

a and Offsite Dose Calculation Manual; and it is logistically important to make the new speicfications effective at the beginning of a calendar quarter.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY KF /r l4tm.au~

b/

/

V. G. Counsil Vice President Attachment 1293 319

DOCKET NO. 50-213 HADDAM NECK PLANT INTERIM COMPLIANCE WITH 40CFR190 1293 320 NOVEMBER, 1979

ATTACHMENT l_

CONFORMANCE WITH 40CFR190 HADDAM NECK PLAMT 40CFR190 Limits - 12 Consecutive Months - Total Dose to Real Individual Whole Body

- 25 mrem Thyroid

- 75 mrem Other Organs

- 25 mrem Demonstration of Compliance In order to ensure compliance with the above limits, dur'ig the interim period, from December 1,1979 until the proposed Radiological Effluent Technical Specifications are implemented, the attached calculations will be completed on a monthly basis. Calculations will be completed within 30 days from the end of the month. The first calculations will be performed for the month of December,1979 and will be completed by January 30, 1980.

The calculations given are taken directly from the proposed Offsite Dose Calculation Manual as submitted to the Commission on August 1,1979. As indicated in the ODCM, these simplified calculations are conservative, and will, therefore, ensure compliance with the limits.

Should these calculations indicate doses in excess of the limits, the more detailed, and hence, less conservative and more accurate calculational techniques as given in the ODCM will be used to validate those determined by these preliminary calculations.

I293 321

CALCULATION SHEE_T_

I.

LIQUID DOSES A.

Monthly ble Body Dose = 3.45 Cp + 3.3 x 10-6 CT = (1) arem B.

Monthly Thyroid Dose

= 4.82 Cp + 3.3 x 10-6 CT = (2) mrem C.

Monthly Organ Dose

= 4.82 CF + 3.3 x 10-6 CT = (3) mrem Where:

CF = Total Gross Curies of Fission and Activation Products, excluding Tritium and Dissolved Noble Gases, released in Liquid Effluents during the Month (See Note 1).

CT = Total Curies of Tritium in Liquid Effiuents for Month.

II.

CASEOUS DOSES A.

Monthly ble Body Dose ' 2.3 x 10 4 CN = (4) mrem B.

Monthly Thyroid Dose

= 5.3 x 103 CI + 3.3 x 10-3 CT = (5) mrem C.

Monthly Organ Dose

= 5.0 x 102 Cp + 3.3 x 10 3 CT = (6) mrem Where:

CN = Total Curies of Noble Gases Released During Month.

CI = Total Curies of I-131 Released During Month.

CT = Total Curies of 2ritium Released During Month.

Cp = Total Curies of Particulates (Tl/2 > 8 Days) Released During Month (See Note 1).

III.

DIRECT DOSE A.

Monthly b le Body - Result of Skyshine Calculation Plus Direct Dose From Other Possible Sources (e.g., Onsite Solidified Waste Storage) = (?) mrem IV.

TOTALS - DOSE SINCE DECEMBER 1, 193 hie Body Dose = Previous Total * + (1) + (4) + (7) <_ 25 mrer.

Thyroid Dose

= Previous Total * + (2) + (5) <_ 75 mrem Organ Dose

= Previous Total * + (3) + (6) < 25 mrem 1293 322

Calculation Sheet Page 2

  • - Total from December 1, 1979 as calculated the previous month. This is only applicable through November, 1980, at which point the first month should be deleted from the total each month.

Note 1 - Excluding Sr-89 and Sr-90.

Strontium results are not available within 30 days following the end of the month, and experience has indicated that they do not contribute significantly to the doses.

1293 32

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N o UNITED STATES y

  • ,7, NUCLEAR REGULATORY COivimisslON

.j WASHWGTON. D. C. 20655 e

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September 17, 1979 TO ALL POWER REACTOR LICENSEES Gentlemen:

The effective date for implementation of the EPA Uranium Ft,.r1 Cycle Standard, 40 CFR Part 190 for light-water reactors, is December 1,1979.

By agreement, NRC is responsible for the implementation of this standard for licensed power reactors. Compliance with Radiological Effluent Technical Specifications (RETS), NUREG-0472 (Rev. 2) for PWRs or NUREG-0473 (Rev. 2) for BWRs, implements the LWR provisions to meet 40 CFR Part 190. Due to the delays in receiving and processing these Technical Specifications as scheduled in the lettar to you from B. Grimes, Assistant Director for Engineering and Projects, dated November 15, 1978, the Radiological Effluent Technical Specifications may not be in effect for your facility on December 1,1979.

The lack of Technical Specifications which implement the provisions of 40 CFR Part 190 '? es not relieve you of the responsibility to confom to the EPA standard. Therefore, you should determine how you will demonstrate to the NRC conformance with the provisions of 40 CFR Part 190 until such time as the revised RETS are issued. A comitme1t to the provisions of Specification 3.11.4 of the RETS, Revision 2, as explained in Chapter 3.8 of NUREG-OlM, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants" is an acceptable method for demonstration of conformance. This comitment or an alternative method of demonstrating compliance with 40 CFR Part 190 should be submitted to NRC no later than November 1,1979.

If you have any questions, please contact us.

1293 324 Sincerely, S.[

ps William P. Gamill, Acting A.sistant Director for Operating Reactor Projects Division of Operating Reactors

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