ML20023B856
| ML20023B856 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/02/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 22038, NUDOCS 8305060483 | |
| Download: ML20023B856 (3) | |
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Consumers l
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@e President - Projects, Engineering asl Custmetion General offices: 1945 West Parnell Road. eckson, MI 492o1 * (517) 788-0453 i
May 2, 1983 s
j Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Comission j
Washington, DC 20555 MIDLAND ENERGY CENIER PROJECT MIDLAND DOCKET NOS 50-329, 50-330 DELETION OF HOGGING AIR EJECTOR RADIATION MONITORS AND DISCUSSIDN OF TRITIUM SAMPLING REQUIREMENTS FILE 0927.3 SERIAL 22038 This letter formally documents the results of a telephone conversation between 1
the NRC (R Hernan and J Lee) and CP Co (D A Sommers, T K Postlewait and J M Tozser) on April 13, 1983. As a result of this telephone conversation, the Midland FSAR Chapter 11.5 commitment to provide hogging air ejector radiation monitors has been deleted and further discussions on the potential relaxation of tritium sampling requirements have been deferred until the NRC review of the Radiological Effluent Technical. Specifications (RETS). FSAR Chapter 11.5-will be revised accordingly during the next scheduled amendment to reflect this agreement.
Hogging Air Ejector Radiation Monitors:
The Midland Project previously committed in Chapter 11.5 of the FSAR to monitor the hogging air ejector effluent for radioactivity based on guidance i
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given in the Standard Review Plan. Since that time, the design of the plant has evolved affecting the method of hogger operation.
In the present design, auxiliary boiler steam is used for operation of the hogging air ejector to initially draw a vacuum on the condenser. Likewise, auxiliary boiler steam is used for turbine seals during startup. The steam used for the turbine seals is then exhausted to the' condenser of the unit undergoing start-up.
It is noted that this steam will not be radioactive (other than activity levels present in the natural water).
The hogging air ejector is used until a vacuum of 15" Hg is developed in the condenser. At that point, condenser vacuum is maintained by the condenser air ejector. The main steam isolation valves and turbine bypass valves remain closed until 20" Hg vacuum (10" absolute) is attained. For this operational procedure, the only radioactivity available for release through the hogging 8305060483 830502 V
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air ejector pathway would be those non-condensable gases trapped in the condenser following shutdown. Such trapped gases do not consitute a significant source of radioactivity.
The Midland Plant design has two permanent auxiliary boilers that can be used to produce steam for the above operations. Although steam from the auxiliary boilers would normally be used for these functions, main steam from the other unit could be used if auxiliary boiler steam were unavailable.
In this mode of operation, the effluent from the hogging air ejector stack could potenti-ally be radioactive. However, the radioactivity of this effluent would be known since the main steam from the other unit is already monitored via the main steam sampling system liquid monitor and the other unit's condenser air ejector monitor.
Based on the above, the hRL agreed to the deletion of the hogging air ejector radiation monitors subject to the following Technical Specification commit-ment.
If main steam is to be used to operate the hogging air ejector, the level of radioactivity in the main steam shall be determined by sarpling and lcboratory analysis prior to hogger operation in order to accurately assess radioactive releases via this effluent pathway. This is to be performed in addition to the main steam monitoring capabilities presently provided in the design.
Tritium Sampling Requirements The issue of sampling and analyzing for tritium in gaseous effluents was independently raised in an earlier discussion on April 13, 1983 between the NRC (R Hernan and J Lee) and CP Co (D A Sommers). During that discussion, the issues of lower limit of detection, methods for determining water vapor content in the effluent and sample frequency were raised in terms of FSAR Chapter 11.5 commitments. CP Co requested clarification as to whether the requirement for tritium sampling of gaseous effluents is justifiable based on the amount of tritium estimated to be released per the Final Environmental Statement.
It was pointed out that 10 CFR 20 permits treating a radionuclide as "not present" if the ratio of the concentration of the radionuclide in the mixture to the concentration limit for that radionuclide does not exceed one-tenth. The NRC suggested that for specific effluent pathways, tritium sampling requirements could be significantly relaxed with sampling frequencies more closely related to those when tritium releases would be anticipated.
It was agreed to defer immediate action to resolve this issue and to address it as part of the NRC review of the Midland proposed Radiological Effluent Technical Specifications.
JWC/DAS/fms CC RJCook, Midland Resident Inspector JLee, NRC RHernan, US NRC DBMiller, Midland (3)
DHood, NRC oc0483-1766a131
g CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 22038 Dated May 2, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits this letter documenting agreements between the NRC and the Company on the subject of deletion of hogging air ejector radiation monitors.
CONSUMERS POWER COMPANY By J
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CodT, Vice Presfdent Proj s, Engineering and Construction Sworn and subscribed before me this h day of h a,. /+/[8.
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ficiuly A.feryNotary Pt})flic Jackson County, Michigan My Commission Expires 0< m,.,o, // / f E (7
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