ML20002D634
| ML20002D634 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/09/1981 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM TAC-46471, TAC-46472, NUDOCS 8101210589 | |
| Download: ML20002D634 (10) | |
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Wisconsin Electnc m cann 231 W. MICHIGAN. P.O. BOX 2046, MitWAUKEE, WI 53201 January 9, 1981 Mr. Harold R.
Denton, Director Office of Nucledr Reactor Regulation U.
S.
NUCLEAR REGULATORY COMMISSION Washington, D.
C.
20555
Dear Mr. Denton:
DOCKET NOS. 50-266 AND 50-301 ADDITIONAL RESPONSE TO NUREG-0737 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Our December 23, 1980 letter provided our response to the requirements of NUREG-0737, entitled " Clarification of TMI Action Plan Requirements", as pertains to Wisconsin Electric Power Company's Point Beach Nuclear Plant Units 1 and 2.
In that submittal, we committed to provide the additional informa-tion attached herewith regarding Items III.A.2.2 (Meteorology) and III.D.3.4.1 (Control Room Habitability).
The attached completes our submittal on meteorology for present purposes.
However, as noted in the attachment, the final submittal of our control room habitability evaluation will be provided on or before February 16, 1981.
Please advise us if you have any further questions regarding this submittal.
Very truly yours, l
l l
C.
W.
Fay, Director Nuclear Power Department Attachments N
l Subscribed and sworn to before me This 9th day of January, 1981.
b\\{
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.w Notary Public, State of Wisconsin
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My Commission expires Copy to NRC Resident Inspector s m m 0531 f"
ADDITIONAL RESPONSE TO NUREG-0737 POST-TMI REQUIREMENTS FOR OPERATING PLANTS 4
e Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 III.A.2.2 Meteorology III.D.3.4.1 Control Room Habitability i
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III.A.2.'2 EMERGENCY PREPAREDNESS - METEOROLOGICAL DATA In accordance with NRC requirements concerning emergency prepared-ness at operating nuclear power plants as specified in'10 CFR Part 50.47, Wisconsin Electric Power Company hereby submits plans for the upgrading of meteorological measurements and atmospheric
' transport and diffusion prediction systems at Point Beach Nuclear Plant.
We believe that these plans adequately address the i
essential elements and guidelines set forth in Appendix 2 to Revision 1 of NUREG-0654 and proposed Revision 1 to Regulatory Guide 1.23.
t-Although current Point. Beach Nuclear Plant Technical Specifica-
-tions do not require meteorological measurements, we have been routinely measuring and recording wind speed and wind direction data since. operation'of the plant began in 1970.
These data have been collected at the 150 ft.- level of a meteorological tower located approximately 2,700 f t.
south of the plant and about.
150'ft. west of the Lake Michigan shoreline.
The following is
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a description of our plans for upgrading the meteorological measurements program at Point Beach Nuclear Plant, including
' incorporation of an atmospheric transport and diffusion assess-ment system and provisions for remote interrogation of the meteorological measurements and. atmospheric predictions:
A.
Examination of the Recresentativeness of the Current (Primary) Meteorological Tower Location The current location of the primary meteorological tower 4
will be examined to ensure that meterological data representative of conditions affecting the transport and diffusion of plant airborne releases can be obtained.
Based upon.a site visit and inspection of topor;raphical maps and aerial photos, the location of the tower will be checked to ensure adequate separation distance from any nature or. manmade obstructions which could generate aerodynamic wakes.
Grade at the base of the tower will Rbe compared with the finished plant grade, and the upper tower level (150 ft.) will be compared with plant release height to ensure representative conditions.
Since Point Beach Nuclear Plant is located on the western shore of Lake Michigan, the location of the primary tower should also satisfy the requirement that both lower and upper measurement levels are contained within the thermal internal boundary layer (TIBL) during stable onshore flow conditions.
Available information on TIBL geometries (l)
(1) Knox, N. B. and W. A. Lyons, 1975.
"The Thermal Internal l
Boundary Layer in a Lakeshore Environment During Summer l-Fumigation Episodes."
Presented at First Conference on Regional and Mesoscale Modeling, Analysis and Prediction.
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will be used, possibly supplemented by calculations.using the method of Raynor et al. (1975) (1), to specify an adequate setback distance from the shoreline.
Siting of instrumentation, with respect to the tower structure itself, will comply with applicable guidelines contained in Section C2 of proposed Revision 1 to Regulatory Guide 1.23.
B.
Upgrading of Primary Tower Measurements Program Meteorological measurements will be upgraded on the primary tower to include the following parameters:
1.
Upper level (45 meters) - wind direction, wind speed, and determination of 00; 2.
Lower level (10 meters) - wind direction, wind speed, and ambient temperature; and 3.,
Differential temperature (AT) between levels and precipitation at ground level.
Measurement and recording components of the system will be specified to comply with the digital and analog system accuracy values contained in Section C4 of proposed Revision 1 to Regulatory Guide 1.23.
The primary tower data acquisition system will include redundant digital and analog data recording with digital data sampling ra.tes (except for precipitation) of at least once per minute.
Translator, recorder, and digital data acquisition system hardware will be contained in an environmentally controlled housing to ensure satisfactory component performance.
Both the meteorological tower and the environmentally controlled housing will be supplied with redundant power sources.
System maintenance, inspection and servicing will be patterned after the guidelines contained in Section C5 of proposed Revision 1 to Regulatory Guide 1.23.
The system will be calibrated at least semi-annually and appropriate quality control procedures will be implemented.
C.
Backup Meteorological Measurements Program We are in the process of investigating the feasibility of coordinating efforts with Wisconsin Public Service Corporation which operates the Kewaunee Nuclear Plant located approximately five miles north of Point Beach Nuclear Plant.
Specifically, the feasibility of utilizing each (1) NUREG/CR-0936, " Recommendations for Meteorological Measure-ment Programs and Atmospheric Diffusion Prediction Methods for Use at Coastal Nuclear Reactor' Sites", October 1979, l
page 8, equation 1. l
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site's primary meteorological measurement tower as a backup
-- bo.the' other site's system is being evaluated.
The Kewaunee Nuclear Plant meteorological tower is approximately 180 ft: high and located approximately 1,000 ft. west of
-the Lake Michigan shoreline.
t As an alternate option to using the Kewaunee Nuclear Plant primary meteorological tower for backup purposes, a 10-meter tower or pole will'be installed at about the same distance inland as the primary meteorological tower from which measurements of wind direction, wind speed, and derivation of as would be obtained.
In the event that both primary and backup system c0 as well as primary system AT. values are unavailable, stability will be estimated using a combination of onsite wind speed data and solar insolation information either estimated onsite or obtained from the Green Bay National Weather Service station.
Tower and instrumentation siting and system accuracy criteria for the backup measurements program will correspond to details presented above in Section B for the primary tower measurement program.
Both the backup tower and environmentally controlled housing for associated translator and recording equipment will be furnished with redundant pcwer sources.
D.
Plant Control Room Data Availability Provisions will be made for display and either digital or analog recording of wind speed, wind direction, and stability-related information from the primary, backup, and supplementary lake effects towers (see Section E).
E.
Lake Effects Since Point Beach Nuclear Plant is located on the western shore of Lake Michigan, airborne releases are occasionally affected by stable onshore flow, especially during the spring and early summer seasons, resulting from either lake i
breeze circulations or synoptically driven gradient onshore winds.
Atmospheric transport and dispersion under these circumstances is more complicated than under routine meteorological conditions in flat terrain because of the growth of a thermal internal boundary layer (TIBL) which gradually _ displaces the marine inversion layer with increasing inland fetch.
In order to adequately characterize mesometeorological and site-specific conditions in this coastal setting and to satisfy the NUREG-0654 Appendix 2 (Revision 1) requirement for Class A atmospheric transport and diffusion modeling capabilities which account for local climatological effects, additional meteorological data is required to supplement information available from the primary and/or backup meteorological measurement systems.
Supplementary F
meteorological information to account for the lakeshore environment will be obtained by locating a' secondary 10-meter tower.at or near the lakeshore for the measure-ment of wind direction, wind speed, and the derivation of a0 values. -We are evaluating the potential need for installation of an " inland" 10-meter tower, on the order of several miles from the shoreline, to more adequately characterize spatial variability of the wind field, especially during lake breeze circulations.
Parameters measured at such a tower would include wind speed and wind direction.
As noted in Section A above, the current location of the primary meteorological tower is being examined for repre-sentativeness with respect to adequate exposure conditions as well as for proper placement with respect to TIBL geometry.
In the event it is determined that the present location is too close to the shoreline and physical relocation of the tower is deemed infeasible, we will consider the option of utilizing this location to gather data at 10 meters representative of the marine layer, in lieu of establishing a 10-meter tower on the lakeshore.
F.
Real-Tim'e Prediction of Atmospheric Ef fluent Transport and Diffusion and Remote Interrogration Systems Appendix 2 to Revision 1 of NUREG-0654 requires that all licensees of operating nuclear power plants install a demonstrated system for making real-time, site-specific, estimates and predictions of transport and diffusion during and immediately following any accidental releases in order to assess the consequences of such releases and.to aid in the implementation of emergency preparedness decisions.
The first phase of the development of this prediction system requires the installation of a Class "A" model designed to produce initial transport and diffusion estimates for the plume exposure emergency planning zone (EPZ) within fifteen minutes following the classification of an incident.
The model shall incorporate information on site area topography and local meteorological data, including lake effects.
Appendix 2 to Revision 1 of NUREG-0654 also requires that all systems producing meteorological data and effluent transport and diffusion estimates and predictions at i
l operating nuclear power plants have the capability of being remotely interrogated, in order to provide simultaneous realtime data in the site vicinity to the licensee, NRC Staff, and other emergency response organizations, on demand during emergencies.
This system should possess the capability of accessing meteorological data from all measurement locations and producing transport and diffusion estimates and predictions, using appropriate dispersion model algorithms.
Each remote interrogation site should have a dial-up connection and a functional backup communica-tions link..
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a Although preliminary hardware, software and system design information is not yet available for the real-time prediction and remote interrogation systems, we plan to ultimately integrate current plant computing capabilities into the system designed for accomplishing these tasks.
Details will be provided at a later date in accordance with compensating actions required to be taken by licensees when exercising the alternative to implementation milestone #3, cited on page 3 of Section III.A.2 of NUREG-0737.
G.
Implenientation Schedule for Meteorological Emergency Response Plan As noted in Section F above, we will implement alternative measures to implementation milestone #3 by April 1,
- 1981, since additional time will be required to fully implement all the required elements of Appendix 2 of Revision 1 to NUREG-0654.
A number of compensating actions will be taken in conjunction with the implementation of an operable dose calculation methodology (DCM) and availability of basic wind and stability data in the plant control room, in ggder to qualify for the alternative milestone program.
Although, as noted earlier, Technical Specifications for Point Beach Nuclear Plant do not include meteorological monitoring requirements, we have an ongoing wind direction and wind speed monitoring program at the 150-ft. level of the meteorological tower described earlier in this plan.
This information will be utilized, in conjunction with the determination of stability using the Pasquill-Turner technique (wind speed and solar insolation dependent), until the primary meteoro-logical tower has been upgraded and other planned elements have been implemented as discussed in Sections B, C,
E, and F above.
The operable DCM will consist of a X/Q overlay system for combinations of wind speeds, wind direction, and atmospheric stability covering areas out to ten miles from the plant site.
The dispersion model algorithm used to calculate dilution factors will be patterned after criteria in Regulatory Guide 1.145.
However, fully site-specific transport and diffusion model prediction capabilities will require the incorporation of algorithms needed to account for stable onshore flow conditions as well as the supple-mentary lake effects meteorological data base discussed in Section E above.
We estimate that this work will be accomplished after April 1, 1981, but not later than July 1, 1982.
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Further details concerning the operable DCM which will be l
implemented this April will be provided in the milestone n l
implementing procedures submittal (March 1981).
A complet, functional description of all elements of the upgraded l
program, including system specifications and installation schedules, will be submitted by July 1, 1981.
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III.D.3.4 CONTROL ROOM HABITABILITY EVALUATION As indicated in our December 23, 1980 submittal, reevaluation of the Point Beach Nuclear Plant (PBNP) control room habitability is being conducted by our consultant in connection with the implementation of other Lessons Learned items.
As noted in that submittal, we are unable to submit a final evaluation report at this time.
However, certain of our assumptions are presented below along with our tentative conclusions.
We estimate that our final evaluation will be submitted on or before February 16, 1981.
We have performed a rough bounding analysis of the PBNP control room radiological habitability and have determined that additional refinements are required before a definitive conclusion can be
, reached.
Certain of the main parameters are provided in Table III. D. 3. 4 -1.
The remaining assumptions requested in NUREG-0737 will be provided in our February 16 submittal.
We are presently working to refine our assemptions, particularly for control room volume, fan rates, containment spray credit, and iodine plateout.
It is also anticipated that the control room will, be tested to determine the exact amount of leakage present.
A reevaluation of the control room shielding will also be performed.
The bounding analysis suggests that accident dose rates to the whole body (gamma) are well within the guideline of 5 Rem.
The same analysis suggests that beta skin doses may be slightly above the guideline of 30 Rem; in the event the final analysis confirms this result, appropriate protective clothing will be prov_ded in the control room.
The rough analysis indicated that iodine dose rates.to the thyroid may be substantially above the guideline of 30 Rem.
In the event these calculated estimates remain elevated in our refined calculations, we will consider appropriate modifications to fans, filters, or leak tightness, if necessary.
- However, we are presently evaluating recent studies at Los Alamos and Oak Ridge National Laboratories which indicate that radiciodine releases in nuclear accidents are substantially less than previously assumed.
We note, furthermore, that the Nuclear Safety Oversight Committee in its December 21, 1980 letter to President Carter recommended that "the Nuclear Regulatory Commission and the Department of Energy should be responding more aggres-sively to this important development."
Accordingly, in the very likely event that our final control room habitability i
evaluation is satisfactory except for a calculated iodine dose which would be resolved by more realistic calculation of iodine j
release, we would hesitate to incur significant costs for modifications required only for the sake of an overconservative i
assumption which has been applied in the past.
Our position on this matter will be further clarified in our February 16 submittal.
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We have no significant quantities of chlorine or other hazardous chemical at Point Beach Nuclear Plant.
In addition, there are no other sources or users of such chemicals within five miles of the plant to the best of our knowledge and belief.
Similarly, shipping lanes and rail lines are sufficiently distant so as not to be'of concern.
We are currently reconfirming our understanding of these matters and will include an examination of the likeli-hood of hazardous chemical transportation along the single nearest highway.
We anticipate that our final conclusions will be
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presented in our February 16 report.
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s TABLE III.D.3.4-1 PARAMETERS FOR POINT BEACH NUCLEAR PLANT CONTROL ROOM HABITABILITY EVALUATION SOURCE TERM Based on operation at 1518.5 MWt for 500 days.
RADIOACTIVITY AVAILABLE FOR RELEASE 2.5% of core iodines of which 85% are elemental and 15% are organic (methyl).
100% of core noble gases.
CONTAINMENT LEAK RATE 0 - 24 hr.
0.4% per day 1 - 30 day 0.2% per day CONTROL ROOM METEOROLOGY Wind Speed Wind Direction Occupancy Effective Time Factor Factor Factor X/Q(sec/m3) 0-8 hr.
1 1
1 2.15 x 10-3 8-24 hr.
0.8 0.85 1
1.46 x 10-3~
1-4 day 0.57 0.71 0.6 5.16 x 10-4 4-30 day 0.36 0.41 0.4 1.29 x 10-4 FILTER EFFICIENCIES 99% for Elemental Iodines 90% for organic Iodines Based on testing as provided for in Technical Specification 15.3.12 2A&B
' FAN RATES I
Flow rate through emergency filters is 4,950 cfm.
Of this total
. filtered flow, 75% is recirculation and 25% is makeup.
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