ML20002D850

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Requests Comments on Impact of Encl Tentative Uniform Monitoring Recording & Reporting Guide on Older Reactors
ML20002D850
Person / Time
Site: Humboldt Bay, Big Rock Point
Issue date: 08/07/1970
From: Morris P
US ATOMIC ENERGY COMMISSION (AEC)
To: Haueter R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8101230177
Download: ML20002D850 (6)


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UNITED STATES -

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ATOMIC ENERGY COMMISSION

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9 August 7,'1970 Docket No. 50-155 Consumers Power Company ATTN:

Mr. Robert L. Haueter Electric Production Superintendent - Nuclear 212 West Michigan Avenue Jackson, Michigan 49201 Gentlemen:

As nuclear power plants increase in number and in size, and as interest increases in questions relating to environmental effects of nuclear facilities, it becomes increasingly important that uniform methods be followed for measuring the effluents released into the environment, for monitoring the environmental effects of radiation, for recording the results of this monitoring and for reporting summaries of this information to the Atomic Energy Commission.

At present there is substantial' variation in monitoring practices among the older reactor facilities on effluent monitoring, in the extent of isotopic analysis of radioactive effluent, the choice of standards among these permitted to be used, and the scope and depth of environmental monitoring. The programs are fully adequate to show that effluents are within permitted levels, but other needs exist which make it important to have more explicit and uniform monitoring procedures and recording of information.

The AEC, with comments and advice from the Bureau of Radiological Health, has developed a tentative " Uniform Monitoring, Recording and Reporting Guide" which is_ intended to be used as a model for technical specifications--in fact this guide has been used in part for this purpose for reactors recently licensed. We believe it represents a substantial improvement in the surveillance system.

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Consumers Power Company

- August 7, 1970 Hows

- formally proposing this as a' proposed rule for all u. _..c pswer plants, we are seeking information from a few older facilities on the impact this would have on their operations,-

the difficulties.the transition would entail, che cost, and time.

We would greatly appreciate-your supplying es this information, or other comments on this proposal..

A copy of the' tentative. guide ~is-enclosed.

Sincerely,

\\

Peter A. Morris, Director Division of-' Reactor Licensing-

Enclosure:

I Uniform Mbnitoring, Recording.

and Reporting Guide cc: George F. Trowbridge, Esquire Shaw, Pittman,.Potts, Trowbridge & Madden 910 - 17th Street, N. W.

Washington, D. C.

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UNIFORM MONITORING, RECORDING.AND REFORTING GUIDE' Guide to Monitoring and Recording Requirements (a) Gascous Releases Station records of gross stack release rate of gaseous activity shall be maintained on an hourly basis during periods of release to assure that the specified rates are not exceeded.

Within one month after commercial service of the unit, an isotopic analysis shall be made of a sample of the gaseous activity released.

From chis sample, a-ratio of long lived G>30 minutes) and short lived (30 minutes or less) activity shall be established.. For BUR's,during each day of operation samples of off-gas shall be taken and gross ratio of long lived aad short lived activity determined. When the samples indicate a change in the ratio of greater than 20% from the ratio established by the previous isotopic analysis, a new isotopic analysis shall be performed. An isotopic analysis of off-gas, including tritium, shall be performed at least quarterly. Records of all isotopic analyses performed shall also be maintained.

(b) Halogen Releases Station records of release of iodines shall be maintained on the basis of determinations on all stack and chimney iodine filter cartridges. The filter cartridges shall be analyzed weekly when the noble gas release rate is less than 10% of average annual rate, otherwise the cartridges shall be counted at least twice a week.

'A determination of the percent of I-131 in gaseous effluents shall be performed at least quarterly. Records of all isotopic analyses performed shall also be maintained.

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(c) Particulate Releases l

l Station records of release of particulates shall be maintained on I

the basis of all stack and chimney particulate filter cartridges counted. The filter cartridges shall be counted weekly when the noble gas release rate is less than 10% of average annual rate, l

otherwise the cartridges shall be counted at least tuice a week.

l An isotopic analysis of particulates released will be performed at least quarterly. Records of all isotopic analyses perforned shall also be maintained.

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(d) Liquid Releases Station records shall be' maintained oflthe gross-radioactive-concentration and volume of.each batch of-liquid'effluentireleased; i

and the average _ condenser cooling water flow and length ofi ime t

over which each discharge occurred.

Identification of. radionuclides in a representative sample'of the:

liquid effluent, including determination of the-tritium content, shall be performed and recorded within the first" calendar quarter following-initial full power operation.at least once per' quarter.

i thereafter, and within one month fellowing each refueling, process change, or other operation:which could significantly alter the' mix of radionuclides.

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Each' batch of liquid ' effluent released shall_be analyzed for gross alpha, beta, and: gamma activity and the results recorded.- Should there be any unexplained statistically significant change in' gross gamma activity from the previous analysis, the isotopic composition of the effluent shall be determined.

Guide to Environmental Monitoring Requirements (a) Environmental Levels: Scope of Sampling 2 Surveillance If, on the basis of effluent measurements, projected human exposures-or intakes, taking into account possible physical or. biological reconcentration mechanisms,.do not exceed 3% of those which would be expected to result from continuous exposure to air or water at the concentrations specified in Appendix B, Table II, 10 CFR Part 20, a minimal environmental monitoring program may be carried out.

Such-a program would typically include quaru:rh samples of air, water, and food products at selected locations to be determined on an ad hoc, case-by-case basis.- Its purpose would be to verify that actual exposures and intakes are not likely to exceed 3% of those that might' result from exposure to the Part120 concentrations.

If projected human intakes do exceed 3% of those that might result from exposure to.the Part 20 concentrations, a more comprehensive program is required.. Such a program would require more frequent sampling, more sampling locations, and possibly more sampling media.

Its purpose would be to provide a basis for determining critical nuclides and pathways and identifying critical exposed population groups, so as to be able to estimate actual human intakes.

This level is consistent with the top of Range I, as defined.in FRC Report No. 2.

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Guide to Requirements for Reporting to AEC:* Units. Terms, Reporting Data

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Radioactive Effluent Releases (a) ~ Liquid Releases 1.

Total number of gross curies released, otherLthan tritium and average concentration-(in microcuries.per milliliter) at outfall of discharge canal.

2..

Total number of curies of tritium discharged, and average concentration (in microcuries per milliliter) at outfall of-

. discharge canal.

3.

Total volume (in gallons) of liquid waste released into discharge canal.

4.

Total volume (in gallons) of dilution water used.

5.

The maximum gross concentration released (in 'microcuries per milliliter. averaged over the period of a single release)..

6.

Estimated total curies released, by nuclide~(other than tritium), based on representative isotopic analyses performed.

7.

Percent of applicable limits released, based on nuclide identificaticas performed.

(b) Gaseous Releases 1.

Total' number of curies released of noble ~ gases and of halogens and particulates with half-lives greater than eight days.

2.

Total number of curies of tritium discharged.

3.

The maximum release rate (in curies per second for any one hour period).

4.

Estimated total curies released, by nuclide (other than tritium), based on representative isotopic analyses performed.

  • Reports to be-submitted within 30 days after January 1 and July 1 of each year covering data cellected during the previous six months, with the data summarized on a monthly basis.

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Percent of applicable limits' released based on.nuclide identifications performed.

Environmental Monitoring' l.

For each medium sampled during the'six-month period..the-

. number-of sampling locations, the ; total ^ number of samples, the number of locations'at which levels are found to be significantly.above local backgrounds, and the highest,;

lowest, and the annual-average concentrations or levels;

.of radiation ~for the location ~with-the highest average and description of that location.' -

2.

If levels of radioactive materials in environmental media indicate the likelihood of public intakes'in excess'of'3%

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o those that could result from continuous exposure to the eancentration values listed in Appendix B, Table II, estimates of the likely. resultant exposure to individuals

.,nd to population groups,.and assumptions upon which.

estimates are based. These values are comparable to the top of Range I, as defined in FRC Report No. 2.

3.

If statistically significant variations in off-site environmental concentrations with the time are observed, correlation of these results with. effluent releases.

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However, before formally proposing this as a proposed rule for all nuclear power plants, we are seeking information from a feu older facilities on the impact this would have on their operations, the difficulties the transition would entail, the cost, and tine.

We would greatly appreciate your supplying us this information, or other coments on this proposal.

A copy of the tentative guide is enclosed.

Sincerely.

Peter A. Morris, Director DivisJon of Reactor Licensing

Enclosure:

DISTRIBUTION:

Uniforn Monitoring, Reccrding ACRS (3) and Roporting Guide H. L. Price C. K. Beck cc: George F. Trowbridge, Esquire M. M. Mann Shau, Pittman, Potts, S. H. Hanauer Trowbridge f. Mcdden C. Henderson 910 - 17th Street, N. V.

P. A. Morris Mashington, D. C.

20006 E. G. Case, DRS L. Rogers, RPS T. k. Wilson F. Schroeder D. J. Skovholt R. DeYoung R. Boyd W. Dooly, DR R. Engelken, CO (2)

OGC (2)

P. Howe Docket File PDR DR Reading Branch Reading R. H. Vollmer Licensing Assistant-Technical Reviewer Branch Chief DM/

I (SEE FCET F. 50-3 FCR CCNCURRE!CES)

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M0 7 1970 DocLet No. 50-155 k'

Conou:ners Power Company ATT;;:

Mr. Robert L. Haueter Electric Production Superintendent - Nuclear 212 West Michigan Avenue Jackson, liichigan 49201 Gentleuen:

As nuclear power plants increase in nu:aber and in sito, and as interest increases in questions relatin;; to environt. ental effects of nuclear facilities, it be.:omes increasingly important that uniform methods be folleved for measuring the effluents releaset into the environment, for monitoring the environmental effects of radiation, for recording the results of this ronitoring and for reporting su:nmaries of this information to the Atocic Encrme Corraission.

At present there is substantial variation in monitoring practicer among the older reactor facilities on effluent monitoring, in the extent of isotopic analysis of radioactivo affluent, the choice of standards among thoce permitted to be used, and the scope and dent' of environmental monitoring.

The programs are fully adequate to show that effl'ients are within permitted levels, but other needs exist which make it important to have more explicit and uniform monitoring procedures and recording of information.

The AEC, with conenents and advice from the Bureau of Radiological Health, has developed a tentative " Uniform Monitoring, Recording and Reporting Guide" which in intended to be used as a model for technical specifications-in fact this guide has been used in part for this purpose for reactors recently licensed.

We believe it represents a substantial improvement in the surveillance system.

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