ML19284A599
| ML19284A599 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/09/1979 |
| From: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19284A594 | List: |
| References | |
| NUDOCS 7903150087 | |
| Download: ML19284A599 (2) | |
Text
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Consumers Power Company
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..o February 9, 1979 O
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Mr James G Keppler Office of Inspection and Enforcement Region III US Huclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICE:iSE DPR SIG ROCK POINT PLtGT - RESPONSE TO IE INSPECTION REPORT NO 50-155/78-11 Censumers Power Co=pany was requested by letter dated January 18, 1979 to respond to an item of concern identified during IE Inspection 50-155/73-11.
The specific issue raised and Consu=ers Power Co=pany's response are as follows:
Frc= the subject Inspection Report:
"We are concerned about your use of the NaI detector to quantify effluent releases. As discussed in Paragraph 3 of the enclosed inspection report, several disagreements resulted frc= your failure to detect certain radio-nuclides using the IaI system. Although the total activity that you quan-tified on the particulate filter was approximately the same as the total activity reported by the NEC's Reference Laboratory, the maximum permissible concentrations contained in 10 CFR 20, Appendix B, are more restrictive for certain radionuclides not detected by the NaI system than the concentrations for the radionuclides reported (for example, Cs-134 and Mn-54). We are concerned that a future release could exceed regulatory limits for a radio-nuclide not detected by the NaI system.
Please inform this office in writing within twenty days of your receipt of this letter of the actions you vill %ke to insure that no regulatory limits are exceeded during the times you consider it absolutely necessary to quantify effluent releases using the NaI detector."
7903I50087
Response
Gaseous Release Analysis The stack gas carbon and particulate filters are replaced after a seven day sample period and are allowed to decay for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to reduce short-lived radionuclide interference during the analysis. Therefore, the analysis is an "after-the-fact" analysis.
FEB 121979
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For several yearn, our administratis e off-gas release rate has been k0,000 pCi/sec. During this time, the releases for particulates have been generally less than 1 x 10-2 percent of Technical Specifications limits and less than 3 x'10-2 percent of Technical Specifications 1Lnit for halogens (I-131). Our records indicate that activation and noble gas release rates are typically a higher percentage of the h0,000 Ci/sec ad=inistrative limit.
Thus, real-time off-ga: monitoring and control, as currently practiced, assures that releases do not exceed regulatory limits.
Based on these considerations, it is concluded that 10 CFR 20, Appendix B, IL=its vill not be exceeded in gaseous effluent and our present method of analysis by NaI spectrometry is adequate for confir=atior, that releases have been maintained far below these limits.
Liquid Release Analysis Liquid batch analysis procedures require that all unidentified beta-e=itting components be assigned the maxi =um permissible concentration (MPC) for Sr-90.
This is highly conservative compared to the MPCs for most beta /ga==a emitters found in liquid effluents. This conservatis= adequately compensates for the possibility of nonconservative assignment of MPCs to some gnema emitters.
Consumers Power recognizes that quantitative analysis of ga==a-e=itting nuclides using NaI involves increased uncertaintieu. To better quantify all effluents, future liquid release sa=ples analyzed using EaI will be retained for subsequent analysi: using GeLi. This subsequent analysis vill be per-formed as soon as pra ticalle.
If the GeLi results differ from the previous results by more than the errors inherent in the analysis techniques, the GeLi values vill be substituted fcr those derived by NaI analysis for purposes of periodic effluent release reporting.
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Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforce =ent
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