ML20002D888
| ML20002D888 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/06/1970 |
| From: | Haueter R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Morris P US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8101230306 | |
| Download: ML20002D888 (3) | |
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Es Dr. Peter A. Morris, Director
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Washington, DC 20545
Dear Doctor Morris:
We have the following comments to offer concernin8 your August 7 letter on " Uniform Monitoring, Recording, and Reporting" of radionuclide releases from nuclear power facilities.
In general, isotopic analyses cannot be performed at very low levels of release. This is particularly true when measur-ing halogen and particulate releases to the atmosphere and, in some cases, halogen and particulate releases to the circulating water discharge canal. As a result, when levels of release are low, gr v a radioactivity may be the only practical method of measuring and reportingreleasesincontrasttospecificisotopicpalyses.
We feel, therefore, that c lower limit of about 1 x 10- uCi/ml activity in the circulating water discharge canal and 3 x 10 gossuCi/cc gross particulate plus halogen activity in the stack effluent should be provided below which isotopic analyses are not required.
With respect to gaseous waste recording requirements, many BWRs do not monitor tritium releases. We feel the quarterly requirement of isotopic analysis for tritium to be reasonable.
However, a conservative yet valid calculation of tritium release to the atmosphere can substitute for this requirement. The calculation would make use of known tritium concentration in steam condensate, known off-gas flow rate and assumed 100% relative humidity in off gas released to the stack.
Reporting of releases requires correlation of effluent releases with statistically significant variations in off-site environmental media concentrations. The wording of the requirement seems to leave open the possibility of correlating effluent releases with environmental fluctuations of radioactive materials concentra-tions not of plant origin. Since the reference area method of j
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Dr. Petcr A. Morris, Diractor 2
Novembsr 6, 1970 environmental surveillance is. employed by many facilities,,it would seem prudent to correlate results with effluent releases only when the reference area model shows a difference between local and remote monitoring stations, and further only when it is likely that projected human exposures as a result of environmental monitoring exceed 5% of Part 20 standards.
All other suggested requirements are either being utilized
.at this time, or adjustments of a relatively minor nature can be made 4
to provide a nonitoring, recording and reporting system consistent with the guide.
Yours very truly, DA g
RWS/lf R. L. Haueter Electric Production Superintendent - Nuclear 7
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