ML20002E430
| ML20002E430 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/17/1978 |
| From: | Skibitsky W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20002E421 | List: |
| References | |
| NUDOCS 8101270971 | |
| Download: ML20002E430 (2) | |
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C0mpany s.n... ome..: :nn w.u wen,s.n Av.au..J.ch.on. wea's.a do2cn Ar.. coa. siv 7as oooo March 17, 1978 Mr Janes G Keppler Office of Inspection and Enforcement Region III US Nuclee.r Regulatory Co==ission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKEI 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO IE REPORT 50-155/78-01 By letter dated February 16, 1978, Consumers Power Company was requested to respond to one infraction discussed in IE Inspection Report 50-155/T8-01. The purpose of this letter is to provide the required response.
a Infraction Technical Specification 6.h.l.d requires that the radvaste effluent monitor alarm be set to warn of concentrations which exceed those listed in Column II, Table II, Appendix B of 10 CFR 20.
Contrary to this requirenent, alarm settings for 17 releases made during 1977 ex-ceeded the required levels.
Response
In accordance with Technical Specification 6.h.1.d a process liquid monitor system is provided to (a) give indication of radioactivity trends in process liquid streams which normally contain radioactive liquids, and (b) to warn the operator of radioactivity in process liquid streams that do not normally contain radioactive liquids.
This section specifies the alarm point for any monitors intended to warn the operator of radioactivity in those process liquid streams that do not normally contain radioactive liquids.
It identifies these monitors as the Radioactive Waste System Effluent to Canal, the Circulating Water Dischar6e and the Service Water Return From Reactor Enclosure. The alar = set points for these monitors are to be set to warn the operator when concentrations are present which exec-d those listed in Colu=n II, Ta' ole II, Appendix B of 10 CFR 20.
However, one of
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>these three monitors, the Radioactive Waste System Effluent to Canal, is recog-nized.to serve another purpose:
It is used in conjunction with the liquid vaste disposal system. Technical Specification 6.h.1.d states:
This monitor shall provide an additional means cf checking the activity of vastes being discharged....".During the course of a planned release (the activity of which l
is analyzed in accordance with Technical Specification 6.5 2), the radioactive waste system effluent to canal monitor is considered to be in a-liquid stream.
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nomally containing radioactive liquid.- As such, the alarm set point should be set in accordance with the results of the liquid vaste analysis in order to provid_e an additional means of checking the activity of the vastes being dis-charged.
In smmary, historical interpretation of 6.h.l.d is that the radvaste monitor t s two functions:
1 To monitor during periods of no release, at which times the ala:m should be set at the limits-from Column II, Table II, Appendix B of 10 CFR 20, and 2.
To monitor during release of batches of radioactive liquid, at which times the alarm set point should be set to correspond to the activity of the_ liquid i
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vaste as determined by radioisotopic analysis. This set point would include i
a factor of 2 to facilitate detection of activity greater than that shown
- i by th-e analysis, yet sufficiently high to preclude spurious alarming.
Conflict with the above interpretation has not occurred previously; however,
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it is apparent that Technical Specification 6.k.1.d could be edited to more clearly state this interpretation. To accomplish this, a proposed Technical Specifications change vill be submitted,in May 1978.
Further, the alarm set point for the radvaste monitor during release of radioactive liquid batches v411, henceforth, be based upon the activity of the liquid being discharged utilizing a conservative factor of 2 to prevent spurious alarms.
Evaluation of the monitor operation and alarm setting during periods of no re-lease vill be forwarded in April 1978.
SN William S Skibitsky i
Senior Licensing Engineer CC: Director, Office of Nuclear Reactor Regulation Director,. Office of Inspection and Enforcement
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