ML20002C486
| ML20002C486 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/17/1976 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101100360 | |
| Download: ML20002C486 (4) | |
Text
{{#Wiki_filter:- e q - si Consumers ( Q POVlCr Company General Offices: 212 West Mschigan Avenue. Jackson. Michigan 49201. Area Code 51/700-05S0 March 17, 1976 g-). Director of Nuclear Reactor Regulation f Att: Mr D. L. Ziemann, Chief 4%-- y,f 4f ~ N ,h' g ff. Operating Reactors Branch #2
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US Huclear Regulatory Commission /A i Washington, DC 20555 .e 'yf.y%,m;! 'J' ];; G@'g,h DOCKET 50-155, LICENSE DPR ' j,i,, s; BIG ROCK POINT PLANT "~ By letter dated February 19, 1976 yoa' transmitted guidsinc(wh_ieb-you ' proposed ~ to be used to file information with the Commission conce(ninig;the; requirements of Appendix I to 10 CFR, Part 50. You also observed that'y'Eu"aie preparing additional guidance regarding the formulation of Technical Specifications related to Appendix I and suggested that we defer development of these speci-fications pending completion of your guidance. 2 With respect to your_raquest concerning measures, we intend to adopt or propose to meet the requirements of Paragraph 50.3ha. We have contracted.vith the Environmental Safeguards Division of NUS Corporation, Rockville, Maryland and have efforts under way in the following basic areas: 1. Meteorological Assessment. 2. Radiological Dose Assessment. 3 Appendix I Cost-Benefit Analysis. Proposed TecLnical Specifications revisions will be based upon the above assess-ments and results of the cost-benefit analysis. The scope and description of each basic area of assessment or analysis is described below. 1. Meteorological Assessment for Big Rock Point Two-year average X/Q values are being calculated for the nominal ten (10), twenty (20), forty (h0) and eighty (80) meter levels for 1960-1962 using Big Rock Point on-site meteorolegical data and stability based upon AT measurements. In addi-tion, NUS will utilize two years of National Weather Service (NWS) station data near Big Rock Point for the period of 1960-1962 to calcu'. ate the two-year average i stonoo N O
L ( ^2. I -s X/Q with stability based upon the Pasquill-Turner method. Finally a two-year i average X/Q will be calculated using the most recent NWS data available on tape. These calculations will be made for ground level and stack height sources (with credit-taken in the ground -level case for building wake effects). The most applicable or conservative of the. Big Rock Point datasets will then be selected, based on the maximum sector site boundary X/O value, and will be used for further comparisons. If-the three sets of data (the ~ sre conservative 1960-1962 BRP, 1960-1962 NWS, and most recent NWS) all compare well or the BRP data are con-servative,- then the BRP data are to be used for radiological dose calculations. If the three datasets do not agree well, the most conservative of the three i will be used for subsequent radiological dose calculations. Monthly and annual joint frequency. distributions of wind speed versus wind direc-tion by stability class will'be provided for the standard stability classes, for the chosen conservative datacet, and for a more " realistic" dataset (" realism" is to be determined by professional judgment). Two-year average X/Q values for the 16 radial sectors to distances of up to 50 miles from the plant vi]l be 4 provided for each dataset along with a detailed description of the model used. The model will be in accordance with guidance contained in Draft Regulatory Guide 1.DD. 2. Radiolog*. Dose Assessment for Big Rock Point Radiation dose se commitment will be calculated for each nuclide released -{, to the environmet gaseous and liquid emissions: a. Maximum annual dose to a realistic individual - skin, total body and organ. dose. b. Annual population dose in man-Rem and man-thyroid Rem. i c. Annual air doses for gamma and beta radiations at the maximum dose "nes - ground level location" which could be occupied by individuals (in an l unrestricted area). J Dose contributions will be ranked according to contributing dose pathway. Separate rankings will be performed for liquid and gaseous emissions. Operating emissions will form the basis of the effluent source term for these calculations. Sector populations are being based upon 1970 census data for the area within 50 miles of the site. Population projections will be made to the year 2000 in or-der to cover the 40-year plant life projection. 3. Cost-Benefit Analysis for Big Rock Point A cost-benefit analysis will be performed to show whether or not the predicted population dose could be further reduced by augmenting radioactive effluent control systems for a cost-effectiveness of less than $1,000 per person-Rem ~ or person-thyroid Rem of reduced population dese. In addition, operational procedure changes or removal of several existing effluent control system fea-tures vill be analyzed to determine the system operational mode which would %I P .. ~.
'A' N 3 J not yield predicted maximum individual doses greater than those specified in the adopted Appendix.I to 10 CRF, Part 50 (per reactor) and still could not be augmented according to the $1,000 per person-Rem cost-effectiveness ratio. The resulting operational mode would form the basis for revisions (including possible - relaxation) of Environmental Technical Specifications (ETS). The foregoing description of measures being taken to meet requirements of 10 CFR 50, Appendix I, are not totally consistent with guidance supplsed by Attachments 1 and 2 of the Commission staff's letter dated February 19, 1976. There are several reasons for these differences. Briefly, these reasons are as follow: 1. Specific guidance was not available to Consumers Power Company by the end of 1975, although such guidance had been expected prior to September 1975 (reference letter to R. C. Youngdahl fran Daniel R. Muller deted June 17, 1975). 2. Work involved in defining the approach, soliciting bids, accumulating necessary data base, etc, was judged to entail a minimum of six months' effort. Consequently, scope definition was initiated in early December and contract proposals were solicite2 in letters dated December 19, 1975. 3. Because specific guidance for Consumers Power Campany plants (docketed prior to January 2, 1971) was not available, our best judgment resulted g in choice of measures described in this letter. Where applicable, we at-tempted to follow guidance provided to others (specifically, guidance given Pennsylvania Power and Light, Susquehanna Units 1 and 2, in a letter from Daniel R. Muller dated October 8, 1975). Options in this letter in-cluded cost-benefit analyses based on detailed, realistic models, and at the other extreme, less detailed conservative models for source term, transport pathways, and resultant doses. 4. The approach described in this letter is expected to result in a final submittal which will be in full compliance with Appendix I requirements, including the June 4,1976 deadline. It is our opinion that to substantially modify our approach at this late point in time would result in either a violation of the June h,1976 deadline, an un-satisfactory submittal, or both. We trust that the staff finds our approach to be acceptab1c. We are most interested in meeting with the NRC staff as soon as such a meeting can be arranged. b $S t v Ralph B. Sewell Nuclear Licensing Administrator CC: JGKeppler, USNRC
U.S. NUCLE AR REGULATORY C' ' MISSION DOCKET U I NHC ognu 195
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) 0 (2 769 / NRC DISTRIBUTION FOR PART 50 DOCKET MATERIAL ' TO: FROM: Consumers Power Co. ATE C ENT Jackson, Michigan D.L.Ziemann R.B.-Sewell ATE EC fV_ OLETTEn ONOroRirED PROP INPUT FORM NUMBER OF COPIES RECEIVED @RIGINAL bONCLAS$1FIED OCOeY 40 DE SCRiPTION E NCLOSU RE Ltr. re our ltr. of 2-19-76... Advising n? the prepartion for additional guidance regaroing the Tech. Specss related to Appendix I.. Big Rock Point pg l SAFETY FOR ACTION /INFORMATION ENVIRO SAB 3-23-76 ASSIGNED AD : ASSIGNED AD : Ziemann BRANCH CHIEF : s.-- B_ RANCH CHIEF :_ ~~Q,,, PROJECT MANAGER : PROJECT MANAGER: MIC753~. : Diggs LIC. ASST. ; T INTERNAL DISTRIBUTION I -EREG FILL > SYSTEMS _ SAFETY PT. ANT SYSTEMS FEVTun 'rtcp s-u - NRC PDR IIEINEMAN TEDESCt1 ERNST I_&_E SCHROEDER BENAROYA 6'BALLAR.D A- ~~0 ELD LAINAS SPANGLER p COSSICK & STAFF ENGINE _ERING IPPOLITO MIFC MACCARy SITE TECH ""GA 211LL __ CASE KNIGHT OPERATING REACTORS a-HANAUER SIINEIL STELLO STEPP 1 HARLESS PAWLICKI w.41UIJ:AN (_Yr.lletr 6 OPERATING TECH } M ac,kf g 2-PROJECT MANAGEMENT REACTOR SAFETY EISENHttr SITE ANALYSIS BOYD ROSS SHA0 VOLLMER P. COLLINS NOVAK BAER BUNCH J. COLLIf, HOUSTON ROSZTOCZY SCINENCER c, ,.KREGER PETERSON CllECK GRIMES u MELTZ ,,ee HELT_ EMES AT & I SITE SAFETY & ENVIRC - ? h., a a m SKOVHOLT SALTZMAN ANALYSIS CD s'aied (crf3 RlTIBERG DENTON & MULLER EXTERNAL _ DISTRIBUTION CONTROL NUMBE R L -LPDR: charlovniy _ M [ s.- -NATL LAB BROOKHAVEi! NATL LAB f - TIC REG. V-IE ULRIKSON(ORNL) [/g N IlU [II kbp - NSl_C LA PDR 1DG[ m.. u ASLB CONSULTANTS "UUI L U ll <Ul 1 Il0LDINGLSMji ACRS NRCFORM 195(2 76) ,}}