ML20024A011
| ML20024A011 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/08/1983 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20024A012 | List: |
| References | |
| LAC-9138, NUDOCS 8306150277 | |
| Download: ML20024A011 (5) | |
Text
,
D DA/RYLAND h
[k COOPERA7/VE
- P.O. BOX 817 2615 EAST AV SOUTH
- LA CROSSE. WISCONSIN S4601 (608) 788 4 000 June 8, 1983 In reply, please refer to LAC-9138 DOCKET NO. 50-409 Director of Nuclear Reactor Regulation ATTN:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 APPLICATION FOR AMENDMENT TO LICENSE
REFERENCES:
(1) NRC Letter, Grimes to All Power Reactor Licensees, dated July 11, 1978 (2) 10 CFR 50, Section 50.90 (3) NRC Letter, Crutchfield to Linder, dated April 20, 1983 (4) DPC Letter, Taylor to Crutchfield, LAC-8679, dated October 29, 1982 (5) DPC Letter, Linder to Crutchfield, LAC-8629, dated September 29, 1982 (6) DPC Letter, Linder to Crutchfield, LAC-8335, dated June 9, 1982 (7) DPC Letter, Linder to Miller, LAC-6657, dated November 21, 1979 (8) DPC Letter, Linder to Crutchfield, LAC-8590, dated September 15, 1982 Gentlemen:
[
Reference 1 requested that proposed Technical Specification changes be submitted incorporating the requirements set forth in 10 CFR 50, Appendix I.
Therefore, in accordance with the provisions of Reference 2, an application to g
amend Provisional Operating License No. DPR-45 for the La Crosse Boiling Water g
gA Reactor is hereby filed with three (3) signed original applications, together g
with thirty-seven (37) copies.
N The proposed license change would add Sections 4/5.3 and 4/5.4, " Radioactive
$y Effluents", and " Radiological Environmental Monitoring", respectively, to the Q
LACBWR Technical Specifications to incorporate 10 CFR 50, Appendix I in o requirements. Several other existing sections have been changed or deleted to T
correlate with the new sections. The proposed revised pages of the Technical g
Specifications are attached to this letter. This application supercedes the La.
proposed Technical Specifications submitted in Reference 8.
WP-1.3.2 )
t
Director _of Nuclear Reactor Regulation June 8, 1983 ATTN:
Mr. Dennis M. Crutchfield, Chief LAC-9138 Reference 3' transmitted a list of comments on items which were not completely resolved at the conclusion of the site visit on February 15-17, 1983, by members of your staff and consultants. This submittal addresses all the comments on items listed in Reference 3.
Resolution to item numbers 44, 78 and 82 of Reference 3 are included as proposed Technical Specifications. We have taken exception to item numbers 24, 42, 46, 56, 59, 64, 65, and 79 of Reference 3.
Items 87a and 87b of Reference 3 have been included under a single LCO, which is a variation of standard Technical Specifications. These exceptions or variations are addressed in this cover letter.
Open Item Nos. 24 and 79: The off gas system-from the main condenser is designed to discharge, with delay and filtration, the effluent directly up the stack or compression into waste gas storage tanks. The hydrogen concentration detector, in addition to dilution and recombination features, is in the-off gas routing for compression. The purpose of the hydrogen monitor is to determine whether compression is possible based on hydrogen concentration. If t
LACBWR chooses to use a mode of off gas operation that utilizes dilution-recombination without compression, then the hydrogen detector has no purpose.
This is the preferred mode because the off-gas flow rate is significantly reduced with attendant longer hold up time resulting in reduced radioactivity emissions. The compression mode has never been necessary in the life of the plant and because of existing LCO's on primary water activity and fuel exposure (burn-up limitations), it is not a likely mode of operation.
Therefore, the hydrogen concentration' monitor is not necessary for expected radioactive effluent releases.
Open Item Nos.- 42, 46, 59 and 64: Lower Limits of Detection (LLD) for various instrumentation and the methodology to calculate LLD's are or will be found in
-plant procedures. We believe that it le unnecessary to include LLD's in both plant procedures and Technical Specifications. In addition, adding LLD calculational methodology to the Technical Specifications requires increasing the volume of the Technical Specifications with details that are not related to plant safety.
Open Item No. 56: LACBWR does not have a viable liquid radioactive waste treatment system. Liquid wastes are discharged on a batch basis and are not continuous. Liquid wastes are diluted by LACBWR condenser cooling water discharge and by Genoa No. 3 coal plant's condenser cooling water discharge prior to entrance into the Mississippi River. Each tank is sampled, MPC, calculations are performed and a discharge rate (s) is determined prior to discharging the tank. We feel that, given the historically small amounts of liquid waste activity discharged, a liquid radwaste treatment system has been shown to be not necessary. -We have made changes to plant operations to reduce F
sources of radioactive waste water such as elimination of condensate demineralizer regeneration.
I Open Item No. 65: Special gasecus effluent sampling and analysis after startups, shutdowns and power changes are not included because, historically, neither the Dose Equivalent I-131 concentration in the primary coolant nor the WP-1.3. 2 i-l
j-Director of Nuclear Reactor Regulation June 8, 1983 ATTN:
Mr. Dennis M. Crutchfield, Chief LAC-9138 noble gas effluent activity exceeded the guidelines of the Standard Technical Specifications. LACBWR has LCO's for primary coolant activity, and limits on fuel exposures (burn up). These LCO's correspond to offgas and effluent i
activities which would be more restrictive than the Standard Technical Specifications.
Open Item Nos. 87a and 87b: The requirements for conducting a land use' census and interlaboratory comparison are included under a single specification for Radiological Environmental Monitoring. The details of the radiological environmental program, land use census and interlaboratory comparison are or will be contained in plant procedures and will include LLD's, reporting levels, sample frequencies, locations, and analyses tables and the details of the program using guidance of Standard Technical Specifications.
LACBWR has conducted a radiological environmental monitoring program, including a preoperational program since 1965. No significant plant attributable radionuclide accumulation in environmental samples has been r
i evident since the program was initiated. A land use census has been conducted and is included in NUREG-0191, " Final Environmental Statement Related to the Operation of LACBWR." EPA has supplied samples to Dairyland Power Cooperative as part of an EPA laboratory crosscheck program. In addition, NRC Region III and the State of Wisconsin conduct a confirmatory measurements program with LACBWR. LACBWR has established an interlaboratory comparison with an independent laboratory, who supplies NBS traceable radioactive samples.
We feel that, since the details of radiological environmental monitoring are or will be in plant procedures, it is unnecessary to include details in the Technical Specifications which would increase Technical Specification volume, and are not related to plant safety.
There are other changes in the enclosed submittal, including pages on which only the page number has changed.
Definitions have been incorporated that are necessary to implement the provisions of this submittal.
i Changes on Page 36 were previously requested in Reference 4.
1 Enclosed Section 4/5.5, " Post-Accident Radiation Monitoring Instrumentation",
was previously requested in Reference 5, but was on different numbered pages, and had a different section designation. No other change is made by this submittal.
Section 5 of our present Technical Specifications has had the pages renumbered, with some minor necessary revisions and is included herein.
Paragraph 5.1.4 on Page 5-1 of this submittal has been deleted because the provisions have been incorporated in other parts of this submittal.
i b
WP-1.3.2.
1 I
_, ~,
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i Director of Nuclear Reactor Regulation June 8, 1983 ATTN:
Mr. Dennis M. Crutchfield, Chief LAC-9138 The changes on renumbered Pages 5-3, 5-4, and top of 5-5 were previously requested in Reference 4.
The change of paragraph 5.2.15 on renumbered page 5-5 was previously requested in Reference 6.
The change on renumbered pages 5-9 and 5-17 is the result of the changes in this submittal on radiation monitoring.
The proposed changes on pages 6-16a and 6-17 are submitted in order to implement the provisions of this submittal.
The LACBWR ODCM will be submitted for your information by June 30, 1983.
DPC will implement the Appendix I Technical Specifications which have not already been addressed by existing procedures within six months of receipt of the approved license amendment.
Reference 1 established this submittal to be a Class III Amendment and the appropriate fee has been paid per Reference 7.
The information submitted in this application for license amendment has been reviewed by the LACBWR Committees as prescribed in Technical Specifications.
If you have any further questions, please contact us.
Sincerely, DAIRYLAND POWER COOPERATIVE
((/$f &
(l6 Frank Linder, General Manager l
FL: HAT:TAS:eme Attachments cc:
J. G. Keppler, Regional Administrator, NRC-DRO III NRC Resident Inspector WP-1.3.2 -
Director of Nuclear Reactor Regulation June 8, 1983 ATTN:
Mr. Dennis M. Crutchfield, Chief-LAC-9138 STATE OF WISCONSIN )
)
COUNTY OF LA CROSSE )
all e Per g T g re me this day of June, 1983, the above named, E r ;,.-
r me known to be the person who executed the foregoing instrument and acknowledged the same.
d Not'Tiry Publ@, La Crosse County Wisconsin.
i My Commission Expires February 26, 1984 4
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