ML20024G226
| ML20024G226 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/27/1976 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9102080368 | |
| Download: ML20024G226 (3) | |
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NORTHERN STATES POWER COMPANY w e s w rae o u e, wiw w e sou n s4oi April 27, 1976 l
1 Mr James M Allan, Chief Fuci Facility and Materials Safety Branch Office of Inspection & Enforcement, Region III U S Nucicar Regulatory Commission 799 Roosevcit Road 1
Glen Ellyn, IL 60137
Dear Mr Allan:
l MONTICELLO NUCLEAR CENERATING PLANT Docket No. 50-263 License No. DPR-22 Your letter dated April 8,1976, which was received on April 9,1976, transmitted IE Inspection Report No. 050-263/76-05.
The Inspection Report states at two points that certain items of discussion v'll be referred to the Office of Nuc1 car Reactor Regulation and will be examined at subsequent inspections.
This letter is written to provide clarification for the record of the NSp position on those matters and several other topics discussed with the NRC personnel during their inspection. Our comments will reference the Inspection Report by page number and paragraph designation.
Pane 2. paronraph A and pnne 12, parnnraph h NSP took the position that there are no regulatory requirements or Technical Specifications covering the Monticello plant whfch require the submission of meteorological data. We further pointed out that the NRC Regulatory Guides are not requirements. The discussion that ensued from that point on was with respect to the recommendations contained in Regulatory Guides 4.8 and 1.21 for inclusion with the semiannual effluents report of meteorological data and dose computations.
We have reviewed the impact of a reporting requirement of this nature and find that a considerabic initial investment in manpower, computer programs, consultant hcip and equipment would be required to provide this type of data.
In addition, it would require a continui, g manpower requirement, beyoid that which we currently have availabic, and possibly intermittent or continuous consultant help to provide the data that the NRC proposes to be submitted each six months.
We carried the discussion further with the observation that the NRC is supplied with site meteorology which is used in a connervative manner with plant effluent information to set regulatory limits on radioactive effluents from the plant and highly conservative design objectives. This is coupled with requirements for on extensive Radiation Environmental Monitoring program to confim that the limits
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and design objectives have been set at such a 1cyc1 that there are no unexpected cffects on the environment from radioactive effluent relcanes from the plant. We made the concluding observation that the semiannual submission of meteorological data and dose calculations would appear to be more of a data collection effort 9102000368 760427 PDR ADOCK 05000263 G
P DR
NORTHCRN GTATCG POWCR COMPANY Mr James M Allan
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Page 2 April 27,1976 i
than information that is needed for the assessment of safety related activitien
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and that the manpower and equipment expenditures that would be involved appear to be uwarranted.
Several years ago NSp began work on a research project for providing transmission of meteorological and effluent data from NSp's fossil and nuclear plants to a centralized computer-oriented data collection system. A prototype " digitizing
' transmitter" was built, tested and installed at the Monticello plant on the meteorological tower about nine months ago.
The " digitizing transmitter" operation has been reasonably successful for the purpose intended, but it han not been suitable for use for submittals to the NRC, such as Appendix I compliance.
It was also intended that a teletypewriter would be provided in the Mont leello control room to provide supplemental recording of the " digitizing transmit ter" information.
It should be noted that the Monticello control room already has a wind direction and velocity recorder in operation.
Since the teletypeuriter nyntem la basedo on use of the prototype device, which might be replaced with more nuttabic equip-ment, it has been decided not to install this supplemental equipment in the Monticello control room. Meteorological data continues to be obt ained f rcnn the 300' tower in strip chart form and is retained in accordance with recordkeeping requirements.
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Paragraph h on page 12 riferences a computer printout as being available, but not in use. This is informatMn frc.n the prototype " digitizing trannmi t t er" equipment and is not in a format or of the quality which could be put to beneficial use by the nucicar plant.
It should also be noted that the licensee in currently hand reducing data from the meteorological strip charts in order to obtain a full year of acceptable quality meteorological data in connection with the Appendix I compliance submittal.
This information will update the meteorolonical data that has been provided to the NRC in earlier submittals.
Pane 6. paranrnph 3.a Since the Monticello plant does not have Appendix B Technien) Specifications, the connnent in regard to ECAD maintcining cognizance of aquatic biotn protection con-ditions, reporting to NSS when protection conditions are exceeded, etc., is not applicabic to the Monticello plant at the present time.
The NSS Department docu not have administrative responsibility f or non-radiological sampling as mentioned in the second sub-paragraph.
The NSS responnibility for reduction and computer processing of the meteorological program results is not a routine responsibility but resulted from the needs for obtaining this information on a one-time basis for the Appendix I compliance cubmittal.
The NSS Department has not initiated development of calculational procedures for doso pathway report-ing to the NRC in line with discussion in an earlier paragraph that there are no,
rnquirement s for this at Mont icello.
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NORTHERN GTATES POWER COMPANY
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Mr James M Allan l' age 3 April 27, 1976 Pane 7, paranraph c We are not aware of any computerized system used by the NSS Department for report-ing the results of program audits and inspections to supervision an management for d
their review.
Pane 8. parnnrnph 5 A revised Radiation 1:nvironmental Monitoring Program was submitted to the Commission on October 15, 1975 as a license amendment request; the program has not yet been put into effect since the license amendment has not been iscued by the NRC.
The March 1, 1976 submittal referencel in the inspection report involves interim Technical Specifications en radioactive effluents; the Radiation Environmental Monitoring Technical Specification pages that u::re included with the March 1,1976 submittal vcre included only because there are changes in pagination in this section due to the removal of radioactive ef fluents from Appendix A and their transfer to Appendix B.
Pancs 9-11. paranrnph d The inspection report correctly reflects the increases in IcycIs of I-131 in milk during the cuncer of 1975; however, it does not point out that these icvels have been greatly reduced since replacement of the defective initial 7x7 fuel during
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the refueling outage in October, 1975.
On the bottom of page 10 and the top of page 11, still under paragraph d, there is a discussion of the number of iodine sampics which should be included in the averaging to determine if additional reporting is required on estimates of likely exposures to individuals and population groups.
The Technical Specification re-quirement f'or supplemental reporting is based on the likelihood of intakes in excess of 17, of those that could result from continuous exposures to the concen-tration values of Appendix B, Tabic II, Part 20.
This appears to be similar to design objective reporting. (It is our position that the sampics should be averaged over a calendar quarter and if the average concentrations of I-131 in milk are greater than 2.4pci/1, then the supplemental information would be recjuired)
Yours very truly, W O.
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L 0 Mayer, l'E l
Manager of Nuclear Support Services l
LOM/ak cc:
Victor Stello G Charnoff MPCA - Attn: J W Perman
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