ML19259C055

Ack Receipt of Amend 14 to License R-81.Request Clarification of Environ Considerations in Section C of Safety Evaluation

ML19259C055
Person / Time
Site:	05000054
Issue date:	06/05/1979
From:	Konnerth C UNION CARBIDE CORP.
To:	Reid R Office of Nuclear Reactor Regulation
References
NUDOCS 7906120276
Download: ML19259C055 (2)

Text

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31: J ( J' UNION CARBIDE CORPORATION y MEDICAL PRODUCTS DIVISION P.O. BOX 324 TUXEDO, NEW YO A K 10987 -

TELEPHONE: 914 351-2131

]

June 5, 1979 Mr. Robert W. Reid Operating Reactors Branch #4 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Reid:

We have received Amendment No.14 to Facility Operating License R-81 for our pool-type research reactor and request clarification of the envi ronmental con-siderations contained in Section C of the Safety Evaluation which was enclosed wi th this amendment.

The environmental portion of our Technical Specifications (Sections 3.8, 3.9, and 3.10) were developed based on our belief that these sections were to ful-fill the license requirements of both the NRC and New York State. This belief was based on :tatements made during the meeting on 12/19/77 at which the NRC originally requested that the Technical Specifications include release limits for both NRC and NYS licensed activities on our site. I have attached a copy of Mr. P. Wagner's summary of this meeting which contains the following state-ment: " Representatives of N.Y. State and NRC agreed that the two regulatory agencies would continue to work together so the resulting program will be con-sistent wi th the requi rements of both agencies".

From the Safety Evaluation write-up it now appears that all the time and effort that went into developing this program has only resulted in an interim specifi-ca t i on . It is stated that this Interim designation is based on a determination that there is insufficient data to predict the local meteorological dispersion.

I find this very difficult to understand in view of the availability of a large volume of environmental monitoring data that can be used to measure the local meteorological dispersion directly. At the present time we have four off-site air samplers running continuously and N.Y. State has three. Our envi ronmental monitoring program has been in operation since 1959 and N.Y. State has been sampling around our site since 1961. I f we do not know what the local disper-sion is by now I am not sure we ever will.

The program that we submitted uses measured values of dispersion to determine -

release limi ts. We would like to know why this method is considered to be less -,

acceptable than calculations based on meteorological modeling. We would also like to know the status of the cooperative effort by NRC and N.Y. State to arrive at a single set of release limi ts for our exhaust stack.

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i) 79061202 % 2284 064

u. s Mr. R.W. Reid June 5, 1979 U.S. Nuclear Regulatory Corrrnission ,

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At the present time we are very reluctant to devote the necessary effort and ~

expense to a program which apparently will be obsolete when new limits 'are negotiated with N.Y. State in January 1980. Since it will take a considerable amount of time to set up this program, this means it could be in effect for less than four months. We find this very hard to justify. We feel that it would be more reasonable for NRC and N.Y. State to work together and agree on one set of release limits before we modify our existing program.

Your timely response to this letter will be appreciated.

^

Very truly yours, t

meuwd S.. J Konnerth

,,'Ma ager Heal th, Safety & Envi ronmental Affairs CJK:.b enc.

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