ML20032D424
| ML20032D424 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/20/1975 |
| From: | Oestmann M Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8111140526 | |
| Download: ML20032D424 (11) | |
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JUN 10 M Docimt Nos. 50-3 /
i 50-247 i
50-286 I
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Applicant: Consolidated Edison Company of New York, Inc.
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Dates:
March 14, 20 and April 10, 1975 i
Facility:
Indian Point Units Nos. 1, 2, and 3-Radiological Environmental f
Technical Specifications.
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On March 14, 20, and April 10, 1975 meetings were held with representa-tives of Consolid4ted Edison to discuss the radiological environmental l
technical specifications which will be incorporated in the Technical Spec-ifications for Indian Point Units Hos. 1, 2, and 3 to be iscued with the j
Operating License No. DPR-64 for Unit No. 3.
Those specifications dis-cussed include Sections 2.4 and 3.4 Radioactive Discharges and Section !. 2
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Radioln,qical Environneatal Surveillance, which are of interest to the i
Efflunt Treatment Systems and Radiological Assess:nent Branches.
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Details of the discussions of the meetings are presented in I*nclosure 1.
A list of attendcus is presented in Enclosura 2.
Items of specificationa 4
submitted and commented on by the applicant are presented in Enclosure 3 4
j and 4.
e Mary Jane Oestmann Environmental Project Manager Environmental Projects Branch No. 1 Division of Reactor Licensing
Enclosures:
As ntated Distribution en n M. Aycock Docket File J. Kastner P. Erickson (Environ) 18 "#
NRCPDR Local PDR NRR Reading G. Knighton pby M.
stmann D. Mt:3.er, ADEP I()
1 T Te esco 8111140526 750620 ray /
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PDR ADOCK 05000 J.Coilins F. Fraley, ACRS(3)
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ENCLOSURE 1 DETAILS OF MEETINGS ON RADIOLOGICAL ENVIRONMENTAL 1
TECID,. CAL SPECIFICATIONS CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
1 DOCKET NOS. 50-3, 50-247, 50-286 I
Meetings were held with representatives of Consolidsted Edison at NRC Headquarters on March 14 and 20 and April 10, 1975 co discuss the radiolo-gical sections of the proposed Environmental Technical Specificaticns to be issued with the Operating License No. DPR-64 for Indian Point Unit No. 3.
Consolidated Edison initially proposed Section 4.2 Radiological Environmental Monitoring Survey as part of the Environmental Technical Specifications on January 24, 1974. After a meeting held on March 8, 1974, the applicant submitted revised pages to the Environmental Techni-cal Specification on April 17, 1974.
The applicant was informed on March 8, 1974, that the proposed radiological environmental program including two regimes would require revision to comply with the NRC guidelines to be published in Regulatory Guide 4.8 Guide to Preparation of Environmental Technical Specifications.
Furthermore, the applicant was told that Section 3.9 Effluent Releases in Appendi.x A of the Techni-cal Specifications would be transferred to Appendix B of the Technical Specifications as Sections 2.4 and 3.4 Radioactive Discharges for Indian Point Unit No. 3.
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On March 14, 1975, the applicant received a copy of a draft of the revised Sections 2.4 and 3.4 Radioactive Discharges and Section 4.2 Radiological Surveillance, for the Appendix B, Environmental Technical Specifications.
Comments on these sections were received from the applicant on March 14 and 20, 1975. They were also transmitted to NRC on April 7, 1975 and are listed in Enclosures 3 and 4.
Additional discussion on the items listed in Enclosures 3 and 4 took place on April 10, 1975. Details of this discussion are presented below.
I.
Sections 2.4 and 3.4 Radioactive Discharges e.
A.
Per Unit vs Site Releases A generic problem exists in that the Sections 2.4 and 3.4 were written for limits on releases from each Unit rather than i
for limits on releases from the entire site.
Since the three Units have common facilities, particularly the steam generator blowdown interties from Units Nos. 2 or 3 to the Unit No. 1 i
SBBPS and the common discharge structure, the releases from i
each Unit cannot be differentiated. The applicant can maintain
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the overall site limit but not on a per Unit basis.
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This issue has been resolved by modifying the wording and including item 1.18 in the Definitions section.
Item 1.18 says l
that:
"The release rate per site shall be equal to the release rate per reactor times the number of reactors producing radioactive effluents at the site irrespective of the e
actual release rate from each reactor through the shared liquid radioactive waste treatment systems."
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B.
Effluent Control Monitor and Automatic Waste Isolation Valve on the Unit No. 1 Waste Processing Plant NRC, staff has required that in Specification 3.4.1.h, Unit No. 1
'I should be provided with a continuous liquid effluent monitor.with recorder, an alarm and automatic closure of each isolation valve, and a continuous flow measurement device with recorder. Since this equipment is presently not at Unit No. 1, the applicant has until June 1., 1976 to install the equipment. Prior to this date, the NRC staff is requiring that all Unit No. 1 liquid effluent releases shall be batch released and any unplanned or uncontrolled offsite releases of radioactive materials in the liquid effluents in excess of 0.5 curies shall require a 10-day notification to the NRC.
t C.
Analysis of Batches of Liquid Wastes The applicant explained that in Specification 3.4.1.b, the requirement that each batch of liquid tastes be analyzed for gamma isotopes is not necessary.
The applicant has used a j
limit of 1 x 10~7 pCi/cc concentration after dilution based on l
gross gammc - beta analyses of each discharge.
The staff i
recommends each batch be analyzed for gamma emitters at a detectable concentration of 5 x 10 7 pC1/ce.
For certain mixtures of gamma emitters, the staff has provided a means of l
calculating concentrations of each radionuclide using measured I
ratios with those radionuclides which are routinely identified i
and measured.
D.
Waste Distillate Tanks at Unit No. 1 Specification 3.4.1.c calls for recirculation of two tank volumes prior to taking samples from a monitoring tank.
it is presently not possible to recirculate the liquids in the Since Unit No. 1 tank, this Specification has been modified to require a recirculation system on'the monitoring tanks at Unit No.L1 by June 1,'1976.
Prior to this time, rcpresentative i
the line with five times the sample line volume. sampl
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3-I E.
Continuous Monitoring and Recording of Radioactivity In Specification 3.4.1.d, the radioactivity in liquid wastes is required to be continuously monitored.and recorded. Conditions are provided whenever the monitors are inoperable. The applicant believes that releases must be allowed after sampling when monitors are inoperable. Unit No. 1 also has no monitors to
. comply with this specification. As stated in item A above, the monitors at Unit No. I will be required by June 1, 1976.
Specification 3.4.1.h describes ~the condition for Unit No. 1 monitoring requirements. However, for the other two Units, if monitors are inoperable for over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, no release from a liquid waste tank shall be made and any release in progress shall be terminated.
F.
Flow Rate Measurements and Recorders In reference to Specification 3.4.1.e, no flow rate measuring devices on Unit No. 1 liquid waste discharge lines and no flow rate recorders on any of the Units exist.
The applicant determines flow rate by recording the time of start and finish of a discharge and the discharge pump capacity.
The volume of liquid in a vaste tank is recorded before discharges. However, Specification 3.4.1.c will require flow rates to be continuously measured and recorded or the tank level checked and recorded at least once every two hours during release.
G.
Blowdown Monitoring In reference to Specification 3.1.4.g, the applicant reported that if the blowlown monitor is out of service, the condenser air ejector monitor will provide for continuous monitoring.
Even if both of these monitors are out of service, the applicant carries out manuc1 sampling which, according to him, will comply with Regulatory Guide 1.21 and Criteria 60 and 64 requirements. The NRC staff will, however, require continuous monitoring and recording of the steam generator blowdown radioactivity.
If these monitors are inoperable, the blowdown flow is required to be diverted to the waste management system and the direct release to the environment shall be terminated.
H.
Limitations on Gaseous Discharges
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The applicant complained that the limits on the radioactive
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gaseous discharges as presented in Specifications 2.4.2.a(1) and 2.4.2.b(1) are more restrictive than the present limits which, according to the applicant, are based on the worst
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meteorology.
In addition in Specification 2.4.2.b(2), the annual limits are more restrictive than the quarterly limits l
which have now been applied. On April 15, 1975, the applicant submitted a letter including revised sections on the gaseous discharge limits.
However, they were later withdrawn. The specifications on the limits have now been firmed up based on l
NRC guidelines, i
I.
Flow Measurements and Recorders of Gaseous Releases As required by Specification 3.4.2.b, gaseous releases, except turbine building ventilation exhaust and as noted in Specifi-cation 3.4.2.c, are required to be monitored. However, no flow measurements or recording instrumentation is provided.
The NRC staff is requiring that the flow of the gaseous releases be measured and recorded by June 1, 1976.
The NRC staff agreed that prior to that date, the release rate in Specifi-
- cation 2.4.2 shall be based on the measured flow rate or the determined flow rate of each operating vent or stack exhaaster, j
provided a flow rate calibration of all exhausters has been performed each 6 months and the damper position and exhauster operating conditions checked and recorded each j
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shift.
J.
Tables 2.4-1, 2.4-2, 2.4-3, and 2.4-4 Based on comments from the applicant, Tables 2.4-1, 2.4-2, 2.4-3 and 2.4-4 were modified such as to take into account the requirements to have various monitors for liquid discharges, which are not in the plant now, installed by June 1, 1976.
The monitors for the steam generator blowdown vents shall be required for Units 1 & 3 by initial criticality of Unit No. 3.
The applicant's comments were taken into account unerever possible.
Sections 2.4 and 3.4 are being finalized and will be included in the Technical Specification to be issued when the Operating License No. DPR-64 for Indian Point Unit No. 3 will be granted.
11.
Radiological Environmental Monitoring Program The radiological environmental monitoring program as described in Section 4.2 of the Technical Specifications for Unit No. 2 was revised by deleting a separate subsection for milk monitoring and incorporating all monitoring in one section for the new Technical Specifications for Units Nos. 1, 2, and 3.
In addition, the i
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monitoring program was revised to climinate the two regime concept l
and to incivde a one regime program consistent with the present day l
NRC guidelines.
Comments on specific items of the revised Section l
4.2 were received from the applicant and are listed in Enclosure 4.
Each item was discussed on April 10, 1975.
As a result on April 15, j
1976, the applicant submitted a revised Section 4.2 to take into j
account his comments. The NRC staff has reviewed the revised j
section, and with some minor modifications, agree with the revised Section 4.2.
Section 4.2 will he issued.as part of the Appendix B l
at the time that the Operating License No. DPR-64 is granted for-j Unit No. 3.
The applicant has also provided two maps locating the j
various sampling stations within 10 miles of the Indian Point eite, j
which will be included in the Technical Specifications.
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List of Attendees L
NRC a
G. W.-Knighton J. Boegli M. Parsont M. J. Oestmann Con Edison J. Kelley R. Van Wyck C. Forsberg i
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Spring l
K. T. Eccelston l
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LeBoeuf, Lamb, Leiby & MacRae l
l E. R. Fidell
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PRCPCSID TEGNIClL @uatrIC3.TIONS P.FP.IL 1975 f
Secticn Pace Preblen 224.b 2.4-1 nis nquires that total liquid ettics relen 2.4.1.b 2.4-3 be tabulated separately for eas reacter. 2;
.2.4.1.c 2.4-3 can ut he dcra because of tb2 'cste treatment 2.4.1.f 2.4-3 interties nardated by the technien specanca, i
2.4.1.d 2.4-3
~ ':here is no "efflhent centrol m: niter" or au s W waste isolation valve" cn tra Unit 1 v prccessing plant. Fven if there is a bnitor.
i wu11d resycnd to dissolved and entrained nob 1; e
gases ard preclude use for dcrenstrating cogliance with 2.4.1.a.
3.4.1.b 2,4-3
'Ihis regiiremen+. for ga-
.sotcpic amlysis.
each relec.ie is not nece~ cry. Ma rcw use a conservr.tive limit of 3x10-/ u ci/cc concent-after di'.utien based en a gress g=ra, beta analysis of each discharge.
3.El.c 2.~4-3 Se waste distillate tarAs on Unit !b. I cans be recirculated so this specificatica cannot 3.4.1.d 2.4-3 Relmses mast be allcwed after sa.plirs when renitors are ircperabic. Srpling can ccrpi i
Reg. Guide 1.21 and Criterien 60 ard 64. Si
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vill cecur den renitern are ircperabic and ccntinues to be prcduced even een the plar.t !
cold shut:ixn.
In addition, Unit No.1 has ri ranih to ccnoly with this crecification. !
3.4.1.e 2.4-3 Sere are no ficw rato reasuring devices en *v i
liquid waste discharge lines and there are rq rata recerclers en any of the Units. Flcv raq kncu.4 ncw by reccr.ir.g. the ti:m of start ard d
of a discharge ard the died.nce ptng capaci j
In addition the volure of liqaid in a waste reccrd:d before dischargo.
3.4.1.g 2,4-4 If the bicw:bn nenitor is cet of service, t ccedenser air ejector renitcr (which is rcro j
sensitive to a les) vill provida centinucus geniteri g and vice versa. Dtn if both of 4 nonitcrs are cut of service, ranual sa.Teling ccccly with R.G.1.21 and CrfA.rica 60 and 64 l
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, requinrents.
2.4.2.a.1 2.4-7 Wis ocw li..dtatica en casecus discharges is; 2.4.2.b.1 2.4-9 nc:a restriccive than the urcsent limits '.#.i-l l
nireaej bastd cn prc;;csed bperdi>: I values l worst:mteorclocy. W.e basis fer the nuih 33 L
restrictive lirit is not identified.
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.4.2.b.2 t 2 2.4-9
'IM cn:x.al li~its, more restrictive than the q.mrterly care now hwn aroHed. Sese did not-exist before wtat is the bW. forlthis limit?.
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)t 3.4.2.b-2.4-8
'bhe::n is no flertreasurir.g er recerfing l
t l-inst:.rentation-on the gasm release po'a+-
T is 6ets. :Lal b.' use of w.tilation '. fan statt n s f
,'. carac:ity.
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...:P.rincibal pu critters en each bats.,, see.
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cc= rent cn 3.4.1.b' ab:we.
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. Table 2,4.2,2.4-20
'Ihc reg ircrent for tritita analysisj.cn ess.
ta:rk ard purge should be replaced by.:Sentinuous tritic.m::nitoring en the plant vent. Se j
centintrus renitering will ec: ply with alf l
requirtm::nts of R.G.' l.21~ and criterion 50'~aW6t
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arx3 win be far less e_ynsive thanl individual "
- sanples, yt' bu,y e..
Table 2.4-3 2.4-22
'Ihis table is very general, can be inte:Noted Irean arrfthing aM sho.11d not be a psh of a pl=
smcification.
Seccifically, the cM.... ical w.
e ta:_ks en Unit 2 & 3 are tra"sferredtto t! e ke 3 3
i systs ard are rot ctherwise renitert,d, Re-i dete~. ant wasta collection tark is.6 shined vite
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cther licuid wastes fcr dischame ahd is.rct C
spu:dieparately..
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2-2 era are no neriters en the servicr;hter.
discharge pipe of any of the Units d.,-2 or 3).
l mere are rc renitors or sepling ofj[ turbine r buildi:q su:ps. Bere are to h2 f. lipaid level 3
ale,:
on aref of the-tanks listod. fl.s.,.
c Ah Tahin 2.4-4 2.4-23 2e sa e general ccrmunt as alxwe api > lies [ 2a
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..is.in contintrus renitor en the vasth case.stora
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tanks. For tritiun renitcring see etcr.unt~cn j
.5 T:tble 2.4-2 abcVe.
to stea:n geWter b1cwdc.c tad. vent will cnly rrenitor for radicicdine.'
mere are no renitors en the t::rbird glerd' seal g
ccndenser cr the redunical wc:mn pp p.
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f INDIAN POII7f l
PIOPOSED TEr. FINICAL SPIEIFICATICNS APRIL 1975 j
I Section Page Problmt I
4.2.1.3 4.2-2 Due to the brief grazing season in this area, any I-changes in numbers of milch animals between the beginning and middle of the grazing season will be minimal. There-fore it is not necessary to conduct two surveys.
4.2.1.4 4.2-3 Since we already have established a control location at Poseton where air and fallout is sanpled, it is unnecess-ary to establish a new station in the least prevalent i
g wind' direction just for food crops. We will sampic focd crops at Poseton.
Tabic 4.2-1 4.2 Sanpling frequency for H.R. aquatic vegetation should
- be Spring and Sunmer. During the fall season very little vegetation is available for analysis.
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It is unnecessary to perfonn Sr-89, 90 analyses since
_ _. _ various technical papers indicate that neasuring Cs-134, 137 will yield the same results.
- Table 4.2-l' 4.2-7
.Sr-89, 90 analysis unnecessary as explained above.
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Control station for leafy green vegetable unnecessary as explained in 4.2.1.4 above.
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Table 4.2-2 4.2-8 Sample point 1 should read Environmental Iab not Air Monitor House since sanpler was relocated to eliminate heavy dust loading.
Sampling point 5 should read NYU tuer not Verplanck lab. The former has been a existing air sanpling station and lies in the same sector as the latter.
'Jherefore no need to change existing sa:rpler.
i Table 4.2-2 4.2-9 Sample points 26 and 27 not necessary since we are i
already sampling H.R. water on a continuous basis.
l Sample point 32, NYU Tower should be sanple point 5.
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Sample point 33, Pover, is not only unnecessary but not
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neaningful as an indicator of plant effects since sanple is moved periodically to different locations.
r Should be eliminated.
- Based on analysis of results of Indian Point 1 and 2 operational radiological environmental monitoring data, the use of Cg-134, 137 measurements as an indicator of Sr-89, 90 in appropriate media is allowed.
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Section Page Problen Table 4.2-2 4.2-10 Sanple point 47 unnr.cessary as explained in 4.2.1.4 above.
Table 4.2-3 4.2-11 Sample size of 1 Kg for H.R. crabs / clams would require collecting 300-400 sanples.. It would be highly improbable that we could collect this many crabs / clams since this:
a ca is not permanent habitat for these organisms.
'Iherefore the mininun detectable concentrati6n will be dependent on the weight of the crabs / clams collected, t
Sr-89, 90 analysis on air particulate required on a monthly / quarterly basis but sanple size indicates weekly sample.
le size therefore should be increased to 1080 m and 3240 m3 for nonthly and quart.crly sampling respectively.
Table 4.2-3 4.2-12 The GSA MDC on milk sample would require sufficiently long enough counting time which would result in a physical change in the sample causing geometry changes.which m uld render the analysis useless. An MDC of 5.0 pCi/1 would be a proper cu.guuise between counting time and j
i detection limits.
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reasons apply to increasing the detection limit frcm 1.0 to 5.0 pCi/1.
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