ML20049H537
| ML20049H537 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion, 05000000 |
| Issue date: | 01/19/1982 |
| From: | Simpson F EG&G, INC. |
| To: | Willis C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20049H530 | List: |
| References | |
| NUDOCS 8203030276 | |
| Download: ML20049H537 (23) | |
Text
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6 6 E 6 'idahS,Inc.
pg p, q g,, g3 idaho Falls. idaho E3401 Janua ry 19, 1982
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Mr. Charles A. Willis Mail Stop P-730 Phillips Building Effluent Treatment Systems Branch U. S. Nuclear Regulatory Commission Washington, D. C.
20555 TRANSMITTAL 0F QUESTIONS FOR THE COMMONWEALTH RETS REVIEW - SIM-2-82
Dear Charles:
Attached are lists of questions pertaining to the RETS and ODCM submittals that will be addressed in our discussion with the Commonwealth plant personnel.
I hope that this will be satisfactory to the project managers in setting up the visit to the plant.
However, it should be understood that there may be additional questions and/or comments at the time of the review with the plant personnel.
Sincerely yours, Ferrol B. Simpson Radiation Measurement Programs Branch jh Attachmant:
As stated cc:
R. E. Ireland, NRC G. L. Vivian, DOE-ID R. W. Kiehn, EG&G Idaho 0
8203030276 820203 PDR ADOCK 05000010 P
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RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) REVIEW I.
Purpose The purpose of this document is to provide licensees with advance notice (i.e., prior to the in-plant review) of areas where further clarification is needed in the review of their RETS submittal'and Off-site Dose Calculation Manual (0DCM).
Some of the areas addressed are such that full compliance with the model RETS is necessary; however,
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in many cases a justified alternative that meets the intent will be i
considered in compliance.
This document is being submitted to the NRC p4ent manager for review.
There are several attachments to this letter. The first is a set of general questions that apply to all the submittals and the remainder are specific to each of the three Commonwealth submittals being reviewed.
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Gennral Qu stions For The Dresden, Quad Cities And Zion RETS Submittals "
Model RETS gq.
BWR/PWR Coments 1.
3.3.7.11/
The submittals all have a section in the 3.3.7.12/
Actions which allows the plant to enter into an operational mode when extenuating circum-stances prevents com' liance to the LC0 and/or p
the Action requirements.
Further clarification i
of this statement and how.it will be inter-l preted is necessary to ascertain compliance.
2.
3.3.7.11/
The Model RETS action "a", for alarm / trip 3.3.7.12/
setpoints being iess conservatively set than required, has not been addressed by the sub-mittals.
This is not applicable to the Dresden Facility.
3.
3.3.7.11/
The Model RETS LCO states that the setpoints 3.3.7.12/
be set such that they don't exceed the limits of specification 3.11.1.1.
This specification is not addressed in the submittals LC0 state-ments.
4.
3.3.7.11/
The Model RETS action "b" is for instrumentation 3.3.7.12/
channels.
The submittals comparable action statement is for monitoring instruments.
Do the instruments used by the submittal facilities only have one channel? This is not applicable to the Dresden Facility.
5.
3.11.1.1/
The Model RETS LC0 stipulates that the con-centration for dissolved or entrained noble gases be limited to a total activity of 2 x 10-4 pCi/ml.
The values listed in the tables associated with the submittals reply to this specification are not as conservative as the above value.
6.
Table 4.11-1/4.11-1 The submittals do not address the analysis for dissolved and entrained gases, gross alpha, or Fe-55 for batch and continuous release of liquids.
7.
Table 4.11-1/4.11-1 The LLD limit stated in the submittals (i.e.
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4.11-2/4.11-2 110% of the values listed in 10 CFR Part 20) is less conservative than the LLD's listed in Table 4.11-1 of th~e Model RETS.
8.
Table 4.11-1/4.11-1 The submittals do not define which radio-nuclides are to be analyzed for when a gama i
emitter analysis is performed.
If the gamma emitter analysis does not include I-131, then this analysis needs to be per-formed with the frequency stated in Table 4
4.11-1.
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s' Model RETS No.
BWR/PVR Comments I-i 9.
Table 4.11-1/4.11-1 The submittals do not state that the sampling frequency for a batch release be prior to each release as required by the Model RETS.
.y.
10.
Table 4.11-1/
The Model RETS defines the at term of the
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4.11-2/
LLD equation to be the midpoint of sample collection and time of counting.
The sub-mittals define the at term as the end of p
the sample collection and the start of the count. The at term should be redefined to be more in line with the Model RETS.
4-11.
Table 4.11-1/4.11-1 The submittals definitin-of a batch release
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does not state how a well-mixed representative sample is to be obtained.
12.
3.11.1.2/3.11.1.2 The submittals-do not address the analysis
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of drinking water when the calculated dose from liquids exceeds the dose limits of
'this specification.
Is this consistent
~-
with the use of the receiving water down-stream from the plants?
13.
3.11.1.2/3.11.1.2 The submittals should change the action of
?
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3.11.2.2/3.11.2.2 this specification to be consiste'nt with 3.11.2.3/3.11.2.3 limiting releases during the current calendar quarter and the subsequent year, not the sub-sequent three calendar quarters, w.
14.
3.11.1.3/3.11.1.3 The Model RETS LC0 u~ es an action point f#
s which is 1/48th of the annual allowed dose via either a liquid or gaseous effluent pathway.
The action points presented in
" J" the submittals exceed the Model RETS action Y
points by a factor of -10.
15.
4.11.1.3.1/4.11.1.3.1 The submittals do not state that the pro-
' I jected doses from the ' effluent be calculated x<
in' accordance with methodology shown in the 0DCM.
7 16, 4.11.1.3.2/
The submittals do not address the 92-day a
4.11.1.2.4/4.11.2.5.2 demonstration of system operability as rbquired by the Model RETS.
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17.
3.11.1.4/3.11.1.4 The reporting option is not necessary to meet compliance to this specification and
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may be remeved.
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18.
3.11.1.4/3.U.1.4 The submittals LC0 statement may be more time cons 0 ming for the utility to determine com-pliance than stating a curie limit on the outside tanks.
7.
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Mod 21 RETS No.
BWR/PWR Comments - -
19.
3.11.2.1/3.11.2.1 The submittals have not used the allowed exception 3.11.2.3/3.11.2.3 for radionuclides with half-lives greater than eight days in the specification for radioiodines and particulates. This may be restrictive to the generating stations.
20.
3.11.2.1/
The submittals do not address the " radionuclides (other than noble gases)" that is required by the Model RETS. This specification is for H-3.
21.
Table 4.11-2/4.11-2 The Model RETS requires analysis for gross alpha and noble gases on continuous release poin'ts. These analyses are not addressed by the submittals.
22.
Table 4.11-2/4.11-2 The superscripts of sampling frequency and minimum analysis frequency for item C Table 4.11-2 of the Model RETS have not been properly used in the submittals.
23.
Table 4.11~-2/4.11-2 The submittals do not define which radionuclides are to be analyzed for when a gamma emitter analysis is per. formed.
24.
3.11.2.6/3.11.2.5 The Model RETS requires monitors for determining 3.ll.2.6A/3.ll.2.5A that the concentrations of both hydrogen and 3.ll.2.6B/3.ll.2.5B oxygen do not exceed limits stated in specifications 3.11.2.6 and 3.11.2.7.
None of the submittals have adequately addressed these technical specifications.
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25.
3.ll.?.7/NA The Main Condenser Model RETS specification has not been addressed by the two BWR facilities.
26.
3.1i.3/3.11.3 The Solid Radioactive Waste Model RETS specification has not been addressed in the submittals.
27.
3.12.1/3.12.17 The Model RETS requires collection of fresh leafy vegetables in the environmental sampling requirements and reporting wh'en they are not available. The submittals do not address these requirements.
Is this consistent with local residential gardening practices?
28.
, 3.12.1/3.12.l' The figures showing environmental sample locations should be moved to the ODCM to facilitate ease of cha'nging these locations in the future. '
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Nodel RETS No.
BWR/PWR Comments T _ _ _.
29.
Table 3.12-1/3.12-1 The Model RETS requires I-131 sample collection on a weekly basis whereas the submittals state sample collection will be done on a bi-weekly basis.
30.
Table 3.12-1/3.12-1 The Model RETS requires two TLD stations to be located in each of the 16 cardinal sectors with eight (8) others to be located at other areas of interest. The submittals do not s
show enough TLD locations. Also, the sub-mittals do not state that two TLD's will be in each station packet.
31.
Table 3.12-1/3.12-1 The gamma isotopic and H-3 analyses listed in the Model RETS for waterborne contaminants are not being complied with explicitly by the submittals.
Also, the sample or exposure pathways are not being fully addressed for waterborne contaminants.
32.
Table 3.12-1/3.12-1 The Model RETS requires milk ~ samples from three locations to be analyzed for I-131 and gamma isotopic.
The subuittals have too few sample locations and are not addressing gamma isotopic analysis.
33.
Table 3.12-1/3.12-1 The Model RETS requires fish to be obtained from a site upstream and downstream from the facility.
The submittals only state one location for a collection site.
34.
Table 3.12-1/3.12 The Model RETS requires collection of food products and gamma isotopic analysis on an annual basis.
Is the lack of this require-ment in the submittals consistent with local agricultural or residential gardening practices?
35.
Table 4.12-1/4.12-1 The LLD's listed in the submittals are not com-plete for all radionuclides required by the Model RETS. The following is a list of the-sample media and the radionuclides not addressed; Airborne Particulates / Cs-134 & 137 Liquids / Mn-54, Fe-59, Co-58&60, In-65, Zr-95, Nb-95, Ba-La-140 Vegetation / Cs-134 & 137 Sediments./ Cs-134 & 137 Animal Tissue / Mn-54, Fe-59, Co-58 & 60,
.Zn-65 i
e Modal RETS No.
BWR/PWR Comments 36.
4.12-1/4.12-1 The Model RETS requires that other peaks which are measurable and identified in environmental samples be reported. This table notation has not been addressed by the submittals.
37.
3.12.2/
The Model RETS requires tha' t the nearest residence and garden be identified in each cardinal se:: tor as part of the Land Use Census specification.
This requirement is not addressed in the BWR submittals.
38.
3.12.2/
The Model RETS action has two parts:
- 1) when a higher dose location is deter-mined, and 2) when the higher dose location has a 20% higher dose.
The first part requires adding the location to the environmental sampling location.
The BWR submittals have joined part 1 and 2 without taking credit for the 20% higher dose clause.
Therefore, they are more conservative than is required and the clause may be added.
39.
6.5.2.8/6.5.2.8 The Model RETS' requires audits and pro-
- 6. 8.1/6. 8.1 cedures of the Quality Assurance Program for the environmental monitoring. These criteria are not addressed by the sub-mittals.
40.
6.9.1.7/6.9.1.7 The submittals do not state that the annual radiological environmental operating report will include summaries, interpretations, and analysis of trends of the results.
Nor do they state the annual report will include a sumary of the monitoring program which includes maps showing locations and tables giving distance and direction of the locations from the facility; or the results of the Interlaboratory Comparison Program.
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41.
6.9.1.8/6.9.1.8' The submittals do not address several items 6.9.1.9/6.9.1.9 required by the Modeh RETS:
a)
The submittals state that they.'ill report w
only the principal radionuclides released in liquid a.nd gaseous effluents. The
~
Model RETS did not restrict the reportin'g to include principal radionuclides.
l b)
The report is to include an hourly summary of meteorological data, i
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Mo' del RETS No.
BWR/PWR Comments 41.
6.9.1.8/6.9.1.8 c) The report is to include 'an assessment 6.9.1.9/6.9.1.9 of doses to the members of the public due to their activities inside -the site boundary.
d) The report is to include an assessment of doses to the public from the uranium fuel cycle sources demonstrating con-formance to 40 CFR 190.
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e)
The report should include all unplanned releases to unrestricted arcos.
42.
6.10.2/6.10.2 The requirement for record retention for records of analyses of radiological environ-mental monitoring samples has not been addressed by the submittals.
43.
6.15.1/6.15.1 The submittals did not address Major Changes to Radioactive Waste Treatment System.
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Dresdin Nuclear Generating Facility v
Drcsden No.
NUREG 0473 Units 1,2,3 Comments 1.
1.0 The submittal did not include definition.
2.
Table 1.2 The submittal did not include a table of frequency notations.-
3.
3.3.7.11.
3.2.F Are the setpoints set to ensure the limits 3.3.7.12 of 3.8.C.1 and 3.8.A.1 are not exceeded?
4.
3.3.7.11 3.2.F Are the setpoints determined in accordance 3.3.7.12 with the ' LCM?
5.
Table Table 3.3.7.11-1 3.2-3 An explanation of the radioactive liquid 3.3.7.12-1 and gaseous release points is required to better ascertain compliance with Tables 3.3.7.11-1 and 3.3.7.12-1.
6.
Table Table Are there any outside tanks requiring 3.3.7.11-1 3.2-3 level indicators?
7.
Table Table Are there radioactivity recorders with 3.3.7.11-1 3.2-3 alarm / trip setpoints?
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8.
Table Table The calibration source must be traceable 4.3.7.11-1 4.2-3 to the NBS.
Are there liquid holdup tanks requiring 9.
3.11.1.4 a curie limit?
10.
4.11.2.1.1 4.8.A.la The Model RETS requires the dose rate to be determined in accordance with the ODCM.
11.
4.11.2.2 4.8.A.2 Is the " total time period" stated in 4.8.A.2 4.11.2.3 4.8.A.3 consistent with the calender quarter and current calender year time periods stated in 4.11.2.27
~
The Ventilation Exhaust System was not 13.
3.11.2.5 addressed in' the submittal.
14.
Table Table Two sample locations are required for the 3.12-1 3.8-2 surface water sample.-
15.
Waterborne The Model RETS requires the monthly composite to be comprised of aliquots taken every two hours. The: submittal states the monthly composite will consist of weekly samples.
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16.
The ground and drinking water items were not addressed.
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Dresden No.
.NUREG.0473 Units 1,2,3 Comments 17.
Ingestion The reporting levels for Cs-134 and Cs-170 appear to be interchanged for the milk sample.
18.
The Model RETS requires milk sampling to be every 15 days when animals are on pasture. The submittal states weekly which is more conservative.
19.
Fish Two locations are required for the fish samples and two species are required.
20.
Food The submittal did not address food products.
21.
4.12.3 4.8.3 The cross che~ck analyses shall be in accordance with the ODCM.
22.
6.9.1.12 The submittal did not address the Prompt Notification With Written Followup Report.
23.
6.9.1.13 The Thirty Day written report is supposed to report when measured levels of~ radio-activity in an environmental sampling medium exceed the reporting levels.
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QUAD CITIES NUCLEAR GENERATING FACILITY Quad Cities No.
Model RETS RETS Pg. #
Comments 1.
1.0 The following definitions were not addressed in the submittal:
Channel Check, Dose Equivalent I-13, Source Check, Process Control Program, Solidification, Off-site Dose Calculation Model, Gaseous Radwaste -
Treatment System, Ventilation Exhaust s
Treatment System, Purge, and Venting.
2.
1.0 The definition for Channel Calibration should include the use of the Channel Functional Test.
3.
4.3.7.11 3.2/4.2-4~
The surveillance statement states that 4.3.7.12 the monitoring instrumentation will be demonstrated operable by performance of the " instrument check, calibration, and functional test operations". These terms are not defined in the submittal.
4.
Table 3.2/4.2-15a The following liquid effluent monitoring 3.3.7.11-1 instrumentation have not been addressed in the submittal:
Component Cooling' Water System Effluent Line gross radio-activity monitor, Discharge Canal flow rate device, and River Discharge Tank level indicating device..Is the lack of these instruments consistent with the plant operation and design such that radioactive liquids could not be released without detection and the.
volume of dilution water is known?
5.
Table 3.2/4.2-15b Action "A" does not state the detection limit for analysis shall be "at least 3.3.7.11-1 10bCi/ml" as required by the Model RETS action 112. Also, the clause allowing for release in a downgraded mode for 14 days is more conservative than the Model RETS and may be changed to 30 days.
6.
Table 3.2/4.2-19 The superscript notations used in the 4.3.7.11-1 3.2/4.2-20 Model RETS for Channel Check, Channel
~
4.3.7.12-1 Calibration, Channel Functional Test have not been properly addressed in the submittal.
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Quad Cities No.
Model RETS RETS Pg. #
Comments 7.
Table 3.2/4.2-19 Instrument surveillance requirements for 4.3.7.11-1 the Liquid Radwaste Monitor Recorder are not presented in the submittal.
8.
Table 3.2/4.2-20 The following system instrumentation 3.3.7.12-1 requirements have not been addressed in the submittal:
Main Condenser Off-gas Treatment System, Explosive Gas Monitoring System, Turbine Building Ventilation Mon-s itoring System, Auxiliary Building Ventilation Monitoring System, Fuel Storage Area Vent-ilation Monitoring System, Radwaste Area Ventilation Monitoring System, and Turbine Gland Seal Condenser Vent and Mechanical Yacuum Pump Exhaust Monitoring System.
Are these areas or systems appropriately monitored prior to release by some other plant ventilation monitors?
9.
Table 3.2/4.2-2 Are the Steam Jet Air Ejector Off-gas 3.3.7.12-1 Radiation monitors equivalent to the Main Condenser Off-gas Treatment System monitors?
Are the SJAE monitors used as noble gas monitors?
10.
~4 11.1.1.1 3.8/4.8-1 The surveillance statement in the submittal 4.11.1.1.3' does not state that the sample analysis results will be used with the calculational methods in the ODCM.to determine the con-centrations are within the linits~ of 3.11.1.1.
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11.
3.11.1.3 3.8/4.8-8 Item.4 has a typographical error "aboce" should be above.
12.
4.11-2 3.4/4.8-21 Table notation "b" has not been used in Table 4.8-1.
The Model RETS requires this notation with itsm "C" of Table 4.11-2.
13.
3.11.2.2 3.8/4.8-1
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The surveillance statement does not state 3.11.2.3 3.8/4.8-3 that the cumulative dose contributions be performed for the current calendar quarter and current calendar year as specified in the Model RETS.
14.
3.11.2.4 3.8/4.8-5 The submittal addresses a gaseous radwaste treatment system in an action statement, however, a LCO type statement has not l
been addressed.'
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Quad Cities No.
Model RETS RETS Pg. #
Comments 15.
3.11.2.4 3.8/4.8-5 The action statement, item 6, is more con-servative than the Model RETS in the time period that the gaseous waste treatment system can operate in a degraded mode.
The submittal may use the seven (7) days allowed by the Model RETS.
16.
3.11.2.5 3.8/4.8-5 The action dose shown in the submittal for operation of the ventilation treatment system exceeds the limits specified in the Model RETS.
17.
3.11.2.5 3.8/4.8-5 The Model RETS action statement for the ventil. tion exhaust treatment system has not been addressed in the submittal.
18.
3.11.2.6 3.8/4.8-5 The submittal's reply to the explosive gas mixture specification does not address any form of instrumentation for measuring the concentrations of hydrogen or oxygen in the main con-denser off-gas sytem.
19, 3.12-2 3.8/4.8-26 The non-routine reporting level of 3 pCi/l for I-131 in water is less _
conservative than required by the Model RETS.
20.
Table 3.8/4.8-26 The Model RETS requires analysis of 3.12-2 sediments to be performed on a semi-annual basis. The submittal is stating this sample will be obtained annually.
21.
Table 3.8/4.8-25 The' submittal is more conservative in 3.12-2 the milk sample frequency during the _
grazing season than required by the Model RETS and may be changed to a frequency of once per 15 days.
6 O
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u.
Zion Station Units 1 and 2 RETS Review Model RETS No.
Specifications Zion Coments 1.
1.11 1.0.F.7 The RET S submittal definition of " Channel l
Functional Test" specifies verification of "setpoints". This should be the more comprehensive " functions" used in the model RETS.
2.
1.19-1.36 1.0 The RETS submittal does not have the follow-ing definitions:
t Dose Equivalent I-131 Process Control Program Solidification Off-Site Dose Calculation Manual Gaseous Radwaste Treatment System Purge - Purging Venting These should be added (if used) for com-pliance with the model RETS.
3.
Table 1.2 The RETS submittal should define the fre-
_ quency "SA".'
4.
Table
- 3. 3.12.1. a, b 3.11.2.1 The following systems are not addressed in the RETS submittal section on Radioactive Liquid Effluent Monitoring Instrumentation:
a) Liquid Radwaste Effluent Line i
b) Steam Generator Slowdcwn Effluent Line Do these lines exist, and can radioactive _
i l
liquids be released through them without being monitored to the extent required in the model RETS?
5.
Table 3.3.12.1.c 3.11.2.1.B Does " Turbine Bldg" monitoring instrumentation addressed in the RETS submittal monitor all liquid effluents which would be expected to be monitored by the " Turbine Building (Floor Drains) Sumps Effluent Line" specified in the model RETS?
If rot, is it possible for radioactive liquids from~ these sumps to be released
.withcut being properly monitored?
l 1
3; _...
w Model RETS No.
Specifications Zion Comments 6.
3.11.2.1. A The Lake Discharge Tank must be discussed to better understand the systems discharged l
and to ascertain compliance.
7.
Table 3.3-12.2 The following liquid effluent monitoring ins'trumentation specified in the model RETS are not addressed in the RETS submittal:
a) Service Water System Effluent Line b) Component Cooling Water Effluent Line
.Do these lines exist, and could radio-active liqi is be released through them without being monitored to the extent specified in the model RETS?
8.
Table 3.3-12.3.a Continuous Composite Samplers and Sampler Flow Monitors for the Steam Generator Blowdown Effluent Line are not addressed-in the RETS submittal.
9.
Table
- 3. 3-12. 3. b 3.11.2.2.A Is " Turbine Bldg Fire Sump" synonymous with
" Turbine Building Sumps Effluent Line" specified in the model RETS?
If so, the Sampler Flow Monitor required by the model RETS is not addressed in the RETS submi ttal.
If not, is it possible for radioactive liquids to be released by this path with-out being monitored by a system meeting th' specification of the model RETS?
e 10.
Table 3.3-12.4 3.11.2.3 Flow Rate Monitors for the following systems are not addressed in the RETS submittal.
a) Liquid Radwaste Effluent Line b) 'Jischarge Canal c) Steam Generator Blowdown Effluent Line 11.
Do these components exist, and is it possible for radioactive liquids to be released through them without flow rates being monitored to the extent specified l
I in the model RETS?
12.
Tables Reactivity Recorders are not addressed in 3.3-12.5 the RETS' submittal.
(Monitorino instrument-ation must be addressed if alarm / trip set-
.pointsarebasedonthemT l
L
^
Modal,RETS
}lt.
Specifications Zion Comments j
13.
Table Tank Level Indicating Devices are not 3.3-12.6 addressed in the RETS submittal. Are these outside storage tanks requiring i
level indicators?
14.
Table 3.3-12 3.11.2 ACTION 28, ACTION 18 - Is Action 18 intended to be comparable to model RETS Action 287 Action 18 in the RETS submittal should include criteria for analysis in accordance with Specification 4.11.1.1.1 in the model RETS if it is to satisfy the same function as Action 28 of the model RETS.
15.
Table 3.3-12 3.11.2 ACTION 31 ACTION 21 - Is the RETS sub-mittal Action 21 intended to be comparable to model RETS Action 31? (Ifso,theRETS submittal is more restrictive than the model RETS - 14 days compared to 30 days allowed with inoperable channels).
16.
Tables l
- 4. 3-12.1. a, b 4.11.2.1 These systems (Liquid Radwaste Effluent Line and Steam Generator Blowdown Line) are not addressed in the RETS submittal.
If they are added to the RETS submittal to comply with model RETS Table 3.3.12.1.a.b, the surveillance criteria corresponding to Table items 4.3-12.1.a,b of the model RETS must also be addressed.
17.
Tables
- 4. 3.12.1. e 3'.11. 2.1. B Surveillance requirements meeting the. criteria of model RETS Table 4.3.12.1.e are required here if " Turbine Bldg" in the RETS sub-mittal includes the " Turbine Building (Floor Drains) Sumps Effluent Line" of the model RETS.
In this case, the Channel Calibration and Channel Functional Test l
criteria must be modified to satisfy the requirements of the model RETS.
18.
Tables 4.3.12.2 Surveillance requirements are not addressed for the following systems:
a) Service Water System Effluent Line b)
Component Cooling Water Effluent Line (See model RETS Table 3.3-12.2 comments' above).
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i Model RETS No.
.,_ Specifications Zion Comments 19.
Table 4.3.12.3.a Surveillance of Steam Generator Blowdown Line is not addressed in the RETS submittal.
(See model RETS Table item 3.3.12.3.a).
20.
Table 4.3-12.3.b 4.ll.2.2. A Surveillance requirements of the model RETS must be satisfied, either by bringing the surveillance requirements in agreement witii those of the model RETS for Turbine Building s
Sumps Effluent Line or specifying release through another appropriately monitored release path.
21.
Table 4.3-12.4 4.11.2.3 Surveillance of Flow Rate Monitors are not addressed for the following systems.
a). Liquid Radwaste Effluent Line b)
Discharge Canal c)
Steam Generator Blowdown Effluent Line These must be added if the corresponding monitoring instrumentation is added to satisfy requirements of model RETS Table 3.3-12.4 22.
Surveillance of Flow P, ate Monitors for the Lake Discharge Tank is not sufficient if sianificant radioactive material is released by this path.
23.
Table 4.3-12.5 Surveillance of Radioactivity Recorders is not addressed in the RETS submittal. This is required if instrumentation is required under Table item 3.3-12.5 of the model RETS.
24.
Table 4.3-12.6 Tank Level Indicators are not addressed in the submittal.
If they are required by Table item'3.3-12.6 of the model RETS, the surveillance requirement is necessary here.
25.
Table 3.3.13
'3.12.2 Is the " Gas Decay Tank" of the RETS sub-mittal synonymous with " Waste Gas Holdup l
System" of the mouel RETS?
26.
Is the " Gas Activity Monitor" of the RETS submittal synonymous with the " Noble Gas Activity Monitor" of the model RETS?
27.
Is the " Air Ejector" in the RETS submittal synonymous with "Condensor Evacuation System" of the model RETS?
i
_ g..-
s-Model RETS No.
Specifications Zion Coments 28.
Table 3.3-13.1.a 3.12.2.1. A Does the gas activity monitor have " Alarm and Automatic Termination of Release" H
specified as required by the model RETS?
(NOTE: Action 25 of the RETS submittal is more restrictive than the model RETS.)
29.
Table 3.3-12.1.b 3.12.2.1.B Action 31 of the RETS submittal does not 3.3-13.1.c 3.12.2.1.C satisfy the intent of Action 41 of the model RETS.
(e.g., Sampling and analysis prior to release, analysis of sample for specific isotopes, and LLD requirements.)
30.
Table 3.3-13.1.d.e The following items are not addressed in the RETS submittal:
a)
Effluent System Flow Rate Measuring Device b) Sampler Flow Rate Measuring Device i
1 Do they exist and meet the intent of the model RETS?
i 31.
Table 3.3-13.2.A B Waste Gas Holdup System Explosive Gas Monitoring Systems are not addressed in the RETS submittal.
Do they exist and meet the intent of the model RETS.
32.
Table 3.3-13.4 Gaseous Effluent Monitoring Instrumentation for Vent Header System is not addressed in the RETS submittal.
l 33.
Is it possible for radioactive gases from this system to be released without being i
monitored to the extent required by the model RETS.
i 34.
Flow -Rate Monitor and Sampler Flow Rate Monitor are not addressed in the RETS sub-mittal for the Vent Header System as required by the model RETS.
35.
Table
- 3. 3-13. 5a 3.12. 2. 3. A The automatic alarm and termination of i
release provisions for the containment purge system are not addressed in the RETS submittal.
Do they exist?
36.
Table 3.3-13.5.d.e Flow rate measurement devices are not addressed 3.3-13.6.d.e in the RETS submittal. Do they exist and.
meet the intent of this item in the model 2
~
RETS?
,-7
+.;, -. -
.f Model RETS Specifications Zion Comments No,.
37.
Tables The Fuel Storage Area Ventilation Radwaste 3.3-13.7 Area Ventilation, and Steam Generator Blow-3.3-13.8 down Ventilation Systems are not addressed 3.3-13.9 in the RETS submittal.
Are releases from' these areas monitored and controlled to the extent required by the specifications of the model RETS?
38.
3.12.2.5 Are the Miscellaneous Ventilation Stack'and 3.12.2.6 Service Building Ventilation systems re-leased through monitored and controlled release points?
39.
Table 3.3.-13 3.12.2 ACTION items comparable to ACTION 38 and ACTION 39 of the model RETS are not in-cluded in the RETS submittal.
40.
ACTION 31 of the RETS submittal (corres-ponding to ACTION 41 of the model RETS) does not contain < sampling and analysis requirements as comprehensive as those specified by ACTION 41.
41.
Table 4.3-13.a 4.12.2.1. A Channel Calibration and Channel Functional Test criteria should meet standards of model RETS entries, with footnotes.
42.
Table 4.3-13 4.12.2 The RETS submittal.should specify a weekly channel check.
43.
4.3-13.1.d 4.12.2.3 Surveillance. requirements should be added 4.3-13.1.e to.RETS submittal corresponding to addition 4.3-13.5 of flow rate monitors to satisfy require-j ments of Table 3.12.2.
44.
Table 4.3-13.2 4.12.2 With addition of a monitoring system for Explosive Gases, the appropriate surveillance requirements should be included in RETS sub-mittal Table 4.12.2.
]
45.
3.11.1.1 3.11.1.A The release limit for dissolved ~or entrained noble gases should bg specified in the RETS submittal (= 2 x 1D-'+ uCi/ml) instead of l
being specified in the ODCM.
46.
4.11.1.1.1 4.ll.A The model RETS specifies analysis of batch releases prior to release.
This specification should be included in the RETS submittal.
~
q n-Model RETS No.
Specifications Zion Connents 47.
3.11.1.1 3.11.5 The " General Specification" statement in the RETS submittal needs further clarification to determine if it can be included and still have the submittal meet the intent j
of the model RETS.
48.
4.11.2.1.2 4.12.1. A.2 RETS submittal should include the require-ment that the dose rate be determined in accordance with the ODCM.
49.
3.ll.2.2.b 3.2.1.c Specification in the RETS submittal should include provisions for reduction of design objectives to provide for releases from turbine building and/or expected public occupancy of beaches, visitor centers, etc.
The Gaseous Radwaste Treatment System and 50.
3.11.2.4 Ventilation Exhaust Treatment System model RETS specification has not been addressed in the submittal.
j 51.
4.11.2.6 4.12.3. A Determination of radioactive materials contained in the tank. should be determined at least once each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radioactive materials are being added to the tank (not once weekly).
52.
3.ll.4.a 3.12.1. F. 2 The RETS submittal specifies " exceeding twice either limi+" but the RETS submittal specifies "twice the limits".
The RETS submittal should include the require-53.
ment for a written report within 30 days as specified in the model RETS.
54.
4.11.4 Method of calculating doses is not addressed in the RETS submittal.
55.
3.12.1 3.16.2 The deviations permitted in this paragraph seem very open-ended. There is a question as to whether they comply with the intent of the model RETS.
The 30 day reporting requirement of the model RETS is not addressed.
56.
4.12.1 4.16.1 The sample locations may be specified in the ODCM instead of the RETS.
(Thisallows changes in sample locations without RETS revisions.)
l l
l l
l
. e.g -
. o. -
Model RETS
- No.
Specifications Zion Coments 57 Table 3.12-1.1 3.16.1.1 The model RETS and the RETS submittal have different conditions of samples requiring gama analysis.
The RETS submittal appears more restrictive.
58.
The model RETS requires gamma analysis on composite samples (by location) quarterly, This is not addressed in the RETS submittal.
s 59.
The RETS submittal does not contain the specification that beta counts be made <24 hours after collection of the samples to allow for decay of short-lived isotopes.
60.
3.12.2 The Land Use Census and Interlaboratory 4.12.2 Comparison Program are not included in 3.12.3 the RETS submittal.
4.12.3 61.
Bases 3/4.3.3.9
- p. 236 Radioactive Liquid Effluent Instrumentation
- p. 236 RETS submittal needs a statement on use and operability of this instrumentation comparable to that in the model RETS.
62.
_ Bases 3/4.3.3.10 p.242j Radioactive Gaseous Effluent Instrumentation RETS submittal should contain statements on provisions for m' nitoring and controlling o
potentially explosive ga's mixtures. Should also contain statement on use and operability of.tne instrumentation.
63.
Bases 3/4.11.1.1
- p. 235 Liquid Effluents Concentration RETS sub-mittal should include.*eference to ICRP Publication 2 as the source of the method of converting to equivalent concentration in water.
64.
Bases 3/4.11.1.2
- p. 235 Statement concerning the equations specified l
in the ODCM for cal'tulating the doses due to actual release rates should be included j
I l
in the RETS submittal.
65.
Bases 3/4.11.2.2
- p. 242j Dose-Noble Gases The last half of this paragraph in the model RETS should be included to specify the methods of calculation.
- i-
- .+
Model RETS No.
Specifications Zion Comments 66.
Bases 3/4.11.2.3
- p. 242j Dose-Radionuclide. Radioactive Materials ir.
Particulate Form and Radionuclide other than Noble Gases, i
67.
Statement of ODCM conformance with Regulatory i
Guide 1.109 i= desirable.
68.
Bases 3/4.11.2.4 Gaseous Radwaste Treatment basis statement is not in the RETS submittal.
69.
Bases 3/4.11.2.5 E'xplosive Gas Mixture basis statement is not in the RETS submittal.
70.
Bases 3/4.11.3 Solid Radioactive Waste and Total Dose bases 3/4.11.4 statements are not in the RETS submittal.
71.
Bases l
3/4.12.1
- p. 280d With changes required in the monitoring programs, there will probably need to be some changes.here in the RETS submittal.
The reporting of unachievable LLD's in the annual report is not addressed in the RETS submittal.
7'2.
Bases 3/4.12.2 Many details in the basis statement for the Land Use Census that are in the model RETS are not included in the RETS sub -
mi ttal.
73.
6.5.2.8.1
- b.(9) and Does a committee audit the environmental 6.5.2.8.m b(13) of monitoring program?
p..
74.
6.9.1.8,9 6.6.3.a RETS submittal specifies monthly summaries of effluent releases instead of the quarterly summaries specified in the model RETS.
i 75.
6.9.1.12.d 6.6.a(10)
RETS submittal does not include specifications for the written foTlowup that are in the model RETS.
76.
6.14.1 6.7.2
" Approval of ODCM by the commission prio.r to implementation" is not included in t.he.
RETS submittal.
77.
6.14.2.1.a 6.7.2.A.1.a Complete specification of the format of the change request is not included in the RETS subw.ittal.
~
eq-Questions For The Commonwealth ODCM Submittals Section 2.1.2.2 (Table 7.2-4)
In the Zion ODCM, there are no dairies within five miles of the plant.
Will the cow-milk R at the 4.5-5.0 mile $ pathway be used assuming that this pathway exists distance in the worst sector? All pathways should be examined.
Secti.on 2.2.1 (Table 7.2-1)
I In the Zion and Dresden ODCMs, values of F" & F liquid flow rates are not given.
In the Zion ODCM, the-additional dilution factor,1/M*, is not valid. The discharge in Lake Michigan is close to the unrestricted area boundary. The concentrations in water should be determined at the release point to the receiving water.
Section 4.1.1 and 4.1.2 s
In the. Zion and Dresden ODCMs, there are references to potable water but the pathway analysis has not been performed.
The credit ta' ken for dilution in fish ingestion pathway at Zion needs to be justified.
The model for dilution in the fish pathway needs to be expanded in the ODCM.
Section 5 12 Zion,'Dresden and Quad Cities The value of compliance status (C.S.) for 10CFR 20 limits should be based on a monthly or a quarterly rate basis instead of an annual basis (1/12 or 1/4 of annual limits).
In this manner, a corrective action can be
-implemented prior to exceeding the annual limit.
Section 7.2 A map of locations of fixed environmental radiological monitoring stations is required for the Zion and Dresden ODCM's.
All three ODCM's require a list of the monitoring stations, distance and direction of each station from the plantj and the type of monitors present.
Section 8,0 The Zion and Dresden ODCMs omitted setpoint calculations methodologies for liquid and gaseous effluents.
6
,