ML20054H269
| ML20054H269 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/09/1982 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20054H270 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM TAC-08140, TAC-8140, NUDOCS 8206230176 | |
| Download: ML20054H269 (19) | |
Text
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Nebraska Public Power District
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June 9,1982 U. S. Nuclear Regulatory Commission Operating Reactors Branch No. 2 Division of Licensing Washington, D.C. 20555 Attention: Mr. Domenic Vassallo, Chief
Dear Mr. Vassallo:
Subject:
Proposed Radiological Effluent Technical Specifications (RETS), Cooper Nuclear Station (CNS), NRC Docket No. 50-298, DPR-46
Reference:
Letter from J. M. Pilant to B. K. Grimes dated January 7,1980, " Radiological Effluent Technical Specifications" By Reference 1, Nebraska Pubhc Power District submitted proposed Radiological Effluent Technical Specifications (RETS), an Offsite Dose Assessment Manual (ODAM), and Process Control Program (PCP) for Cooper Nuclear Station.
In a meeting with the staff April 5-6, 1982, NPPD wu requested to revise the RETS and the ODAM. Enclosed are five copies of these revised documents for NRC review. Substantive revisions to the RETS and ODAM over the version submitted by Reference 1 are denoted by " clouds." The enclosed PCP was not revised, but is submitted for completeness. Enclosures 1 and 2 are listings of all remaining open items from the NRC meeting and brief statements as to which action the District took, as agreed upon by the staff and their contractor, to resolve the issues.
ol o
It must be recognized that upon acceptance of these proposed documents by NRC, a period of time will be required to implement the programs at CNS.
The District's status regarding implementing a Plant Management Information System (PMIS) which will perform these functions will be provided in June,1982. The applicable District safety review boards have not reviewed these latest revisions to the Technical Specifications. Upon acceptance of these specifications by the staff, a copy without annotations will l
be provided along with a commitment as to when these l
specifications can be implemented. Implementation of this program at the beginning of a calendar year is preferable and January 1, 1984, is a possible target date contingent upon replacement of the process computer.
8206230176 820609 i
PDR ADOCK 05000298
[
P PDR
Mr. Domenic Vassallo Page 2 June 9,1982 Technical Specifications for the effluent monitoring instrumentation being installed under NUREG 0737, Item II.F.1 will be provided after receipt and installation of the equipment.
Should you have any questions or require additional information, please contact me.
Sincerely,
%t Ja
- 1. Pilant Director of Licensing and Quality Assurance JMP/jdw:bn9/6R2 Attachments l
l l
l Page 1 of 10 ALL RHfAINING NPPD ACTION ITEMS FROM April 5-6, 1982, NRC RETS MEETING (NOTE: These comments and resolutions are referenced to the original EG&G comment sheet and not the latest CNS Tech. Spec. numbers; i.e., 3.20.A.1 vs 3.21.A.1)
EG&G Item EG&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 1
1.19 A definition for dose equivalent I-131 was Add definition not included.
2b 3.20.A.I.c Action c appears to be more restrictive Change pgs 216m, 216r 3.20.A.2.c than the RETS requirement which states "with less than...."instead of "with a...."
4b Table Table Are the sources strong enough to generate Add word "over" to pg 216q 4.3.7.11-1 4.20.A-1 a signal over the entire range or in the Action 3 Action 3 range as stated in the submittal?
Sa Table Table Is the main condenser off gas treatment Instrument notations were-4.3.7.12-1 3.20.A.2 system monitored by the main stack monitors?
clarified 1
4 If so, are there provisions for alarm and automatic termination of release for this system?
2 2
Is the system designed for an explosion? In Change operable no. from 1 to either case, more monitors are required.
2 on pgs 216t and 216s 122 26 With less than the required number of Add Basis to Action 26 for channels operable, flow rate estimates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are required every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> instead of every 24 as stated in the proposal.
127 29 The following should be adoed to the last Add words to note 29 sentence "...as required in Table 4.20.C.l."
Page 2 of 10 EG&G ltem EG8G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 6
Table Table The channel functional check should be Revise pg 216u as discussed 4.3.7.12-1 4.20.A.2 tested at the Q(1) frequency and not at the regarding NMC and CE monitor 3
3 Q(2) R(1) frequency.
ODAM Figure 3-1 (NPPD initiated change for clarity)
Revise drawing and better reference Table 3.20.A.2 i
Action 3 Action 3 Does the source provide a signal over the Add to note 3 pg 216v range or in,the range?
Action 4 What are the percentages of hydrogen used Revise note 4 on pg 216v to go for the gas standards?
to "one" standard. Pg 216u revise monitor to 2%
10 Table Table The analysis for P-32 is no longer required.
Delete and change note 10 on 4.11-1 4.20.B.1 pgs 216x and 216y Action 1 Action 1 The at component for both the liquid and Definition K.A., the " Lower gaseous instruments is in error. The At is Limit of Detection" has been the elapsed time between the midpoint of deleted.
sample collection and time of counting.
Table 4.20.B.1, note I has been revised to define LLD. When applied to effluent samples, At is the elapsed time between the midpoint of sample collection and the time of counting. To avoid overcorrection for long
,/
cffluent sampling time, a value '
greater than two will not normally be used in the correction term 1/e-At,
/
/
/
/
Page 3 of 10 EC&G Item EC&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution Table 4.20.C.1, note 1, has been revised to refer to LLD defini-tion in Table 4.20.B.1, note 1.
Action 2 The LLD is an "a priori" value. Therefore,'
Add the word "a priori" to the Action 2 could be removed from the tech.
appropriate tables. Delete specs and relocated to a procedure or the defn. K.A. and define LLD on ODCM if desired.
each table.
Action e The definition for a continuous release Add to note 6.
was omitted.
6 Action 6 Is the value of 3 x 10 Ci/ml correct or Revise
-6 was it meant to be 3 x 10 Ci/ml?
Action 10 This program would be beneficial in Delete all note 10 supporting the arguments to delete analyses for Fe-59.
Iloweve r, it is unlikely that this statement will be accepted as part of the tech specs.
11 3.11.1.2 3.20.B b
The annual limits were omitted.
The District has revised the ODAM to be fully responsive to this NRC request.
Action a 2b The special report is in lieu of the Correct b on page 216al and add licensee event report.
"LER" to page 235 12 Action c 3.20.b.2.d The special report (which is in lieu of NRC has accepted NPPD reasoning the LER) is also required if the equipment is inoperable for more than 31 days.
Page 4 of 10 EG&G
~
Item EGaC Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution
,i 13 4.11.1.3.1 4.20.B.2.b The doses are to be projected in accordance Revise page 216al with the ODCM.
16 Table Table The LLD for the noble gas monitor is to be NPPD will revise when new instru-
-6
-6 ments are installed.
If LLD can't 4.11-2 4.20.C.1 1 x 10 instead of 5 x 10 Ci/ml.
be met, District will justify in notes.
Footnotes a
1 The At term in the LLD expression is See resolution for item 10 incorrect.
above.
2 This footnote may not be necessary for The District has opted to leave inclusion in these tech. specs.
this note in e
The model RETS requires weekly 11-3 grab Add note 10 to pg 216a5 samples froa the ventilation exhaust whenever spent fuel is in the spent fuel pool. The proposal does not address this requirement.
17 3.11.2.2 3.20.C.2 b
The annual limits were not included.
The ODAM has been revised to be fully responsive to this NRC request.
Action a 3.20.C.2.b The special report is in lieu of the LER.
Change to 6.7.3.B pg 216a3 The last sentence should contain the statement "...to be taken to ensure the limits of Specification 3.20.C.2a are not exceeded."
Page 5 of 10 EG&G Item EG&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 18 3.11.2.3 3.20.C.3.a The first sentence will require discussion Change pg 216a6 to determine which isotopes are to be included in the dose calculation. The 7.5 mrem is to any organ.
19 3.11.2.4 3.20.C.4a The gaseous radwaste treatment system NRC accepted NPPD operability shall be in operation whenever the main reasoning cendenser air ejector system is in operation. The proposal states it will be in operation whenever certain projected air l
doses are exceeded.
Action a 3.20.C.4.b The special report (in lieu of the LER) is NRC accepted NPPD operability required whenever the gaseous radwaste reasoning treatment system is inoperable for more than 7 days.
20 4.11.2.4 4.20.C.4.a What is meant by the appropriate portions This section clarified of the system are demonstrated operable?
21 3.11.2.5 3.20.C.4.b The special report (in lieu of the LER) is NRC accepted NPPD operability required whenever the Ventilation Exhaust reasoning Treatment System is inoperabic for more than 31 days or if gaseous wastes are being discharged without treatment and in excess of the 3.20.C.4a limits.
22 4.11.2.5.2 4.20.C.4.a Is the ventilation exhaust treatment system Specify in Tech Specs Definition demonstrated operable at least once per which Systems are " vent exhaust 92 days?
systems" 23 3.11.2.6 The volume percent shall be limited Change 4% to 2% hydrogen and 3.ll.2.6A 3.20.C.5 to < 2% by volume of hydrogen and/or delete "or oxygen" oxygen.
Page 6 of 10 EC&G Item EG&C Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 25 3.11.2.7 3.20.C.6 The model should have stated "(100 pCi/sec Revise pg 216a7 a,b per MWt af ter a 30-minute delay)."
28 3.11.3 3.20.E.2 The action to suspend shipments when the Revise E.2 to include provisions Action a packaging requirements are not satisfied of STS 3/4.ll.3.a.
was not included.
The special report (in lien of the LER)
NRC accepted NPPD operability is also required when the solid radwaste reasoning system is inoperable for more than 31 days.
31 3.11.4 3.20.D.1 It appears the proposed reporting is more Add "within 31 days" I
Action a restrictive than required by the model RETS.
I The report may or may not be able to Review RETS 3/4.11.4 and revise demonstrate the 40 CFR 190 limits were not Spec. 3.20.D.1 accordingly and exceeded.
Basis What is the basis for the 10-mile radius?
The variance request is required only if the 40 CFR 190 limits are exceeded and corrective action has not been taken.
32 4.11.4 4.20.D Does the proposed dose calculation constitute Add words to 4.20.D.1 pg 216a8 an additional calculation beyond what is required by the model?
33 3.12.1 3.20.F The reporting requirements are in lieu of Add reference to 6.7.3.B the LER.
Page 7 of 10 EG&G ltem EC&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 35 Table Table 3.12.1 3.20.F.1 Direct Radiation 40 TLD locations are required; 8 are Revise pg 216al2 to a reasonable
- proposed, number Ground Water Two locations are required. One location Pg 216al2 is revised to include is proposed.
2 locations 36 Table Table The food product title was substituted with Relabel to mean food products 3.12-2 6.7-2 broad leafy vegetation.
37 Table Table The words "a priori" should be included Add the word 4.12-1 3.20.F.2 in the LLD definition.
38 3.20.F.5 If the location yields a dose > 20% of an Change pg 216all to define existing location, the new location is to
" exceeds" be added to the program within 30 days and the lowest dose location may be deleted after October 31.
3.20.F.6 Sample location changes would be reported Change to say annual report.
in the special report instead of the Change pg 231 and 231a Monthly Operating Report?
39 3.12.3 3.20.G.1 The Inter-Lab Comparison program must be Add "which has been approved by approved by the Commission.
the NRC" 42 6.8 6.3.2 Written procedures are required for impic-Delete paragraph on pg 235b Procedures mentation of the PCP and the QA program since PCP submitted for effluent and environmental monitoring.
Page 8 of 10 EGSG Item EC&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 43 6.9.1.10 6.7.1.D Changes to the ODAM are to be reported in Change from monthly on page 235b Monthly the semiannual report.
Operating Report Changes to the Environmental Monitoring Add 3 words to page 231a "includ-Program are to be reported in the special ing any changes" report and a summary of the program is to be contained in the annual report.
The statement reporting major changes to Revise pg 231 the radioactive waste treatment system may be deleted. Major changes to any system would be addressed through 10 CFR 50.59, 44 6.9.1.9 6.7.1.F The meteorological data are supposed to be Revise pg 231a Semiannual reported in the January I semiannual Report report instead of the annual report.
The assessment of radiation doses due to Move F to pg 231c and add foot-liquid and gaseous effluents are to be note regarding unrealistic 60-day in the January 1 semiannual report.
limit The January I semiannual report must also include:
a.
Assessment of doses to members of the Respond in Enclosure 2 to discuss public due to their activities inside transients on river the site boundaries. The dose calculations shall be in accordance with the ODAM using meteorological conditions concurrent with the time of release.
i I
Page 9 of 10 EG&G Item EC&G Agreed Upon No.
NUREC 0473 Cooper T/S Comments Resolution c.
Show conformance to 40 CFP.190.
Add words to F on pg 231a and move to page 231c.
46 6.9.1.12 6.7.2.A.10 Items j and k in the model RETS were not Delete 10 on pg 233 and add to Prompt Notification specifically addressed.
pgs 216w and 216a2 48 6.15 6.10 This entire section can be deleted, llowever, Reduce to one paragraph and re-I it could be inserted in the PCP where the ference USAR and 50.59.
information contained would be preserved.
(NPPD's change)
"30 day" reporting require-ments are changed to "31 day" I
reports to be consistent with i
l 31 day operability require-sents.
Table 3.20.A.1 Condensate Storage Tank and Outside l
(pg. 2160)
Temporary Tanks is deleted per NRC guidance 3/421.B.3 obtained in 11/10/81 meeting with AIF Subcommittee on RETS. The piping is routed to radwaste treatment system.
3/4.20.B.2.C Per the NRC " Summary of Draft Contractor (pg. 216a3)
Guidance of RETS" dated May 19, 1982, this specification related to "0PERABLE" deleted.
3.20.A.1 & 2 Times specified in ACTION statements in (pgs. 216n and Table 3.20.A.1 and 2 Notes and referred to 216s) and in Spec. 3.20.A.I.C and 3.20.A.2.C have been Tables 3.20.A.1 deleted.
Specification 3.20.A.I.d and and 2 3.20.A.2.d have been added. This resolves the open-ended problem in the earlier speci-fication and implements NRC guidance.
Page 10 of 10 P
EG&G ltem FG&G Agreed Upon No.
NUREG 0473 Cooper T/S Comments Resolution 3.20.A.I.b. and The word "immediately" is replaced by 3.20.A.2.b "without delay" per NRC guidance.
4.20.B.1 Revised per NRC guidance in revised STS.
(pg. 216x)
Assurance by immediate notification by alarm or control by setpoint that the unrestricted area MPC in water is not exceeded is provided in Specifications 3.20.A.1 and 4.20.A.I.
Verification that the MPC was not exceeded is provided (and required) indirectly by Specifications 3.20.B.2 and 4.20.B.2.
3.20.B.2 The words "after the quarter in which the (pg. 216a3) limit was exceeded" are added.
4 4.20.C.4.a.
The operability demonstration requirement is j
l deleted per NRC guidance in revised STS.
I 6.7.1.D The title and address of the NRC recipient of the monthly operating report have been deleted because they are subject to change.
I I
. - - _ -.. - - _ - _ - _ -. - ~. -
9 Page 1 of 7 Al.i. R101A ll;1!:C !:l'PD M'TIGN IT Fr.S CDCPER NtWl EAR GI24ERATlf;G STATION ODAM REVIEW April %6, 1982, !;RC RETS !!FFTING ODAM FGaC Agreed Upon Section Comments Resolution 2.2 liow was the additional dilution f actor of 5 obtaintd? Reference A mixing ratio of five any study done. IIou far downstre..m is the nearest potable water from the canal was selec-supply? The dilution factor of 5 should not be applied to fish ted for evaluating the pathway.
potential dose to a person who may eat fish or drink water taken from the River near the Station.
There has been no reported withdrawal of Missouri River water within 50 miles down-stream of the Station for drinking or irrigation."
The nearest public utility with water intake down-stream is near Kansas City, about 85 miles away. The nearest anticipated with-drawal for drinking water or irrigation is miles or more downstream. Within either of these distances water from the discharge canal will have mixed with more than five volumes of River water. Downstream dilution of the discharge from the Cooper Station has been evaluated based on the thermal plume studies per-formed at the Cooper Station, Measured values during the
Page 2 of 7 ODAM II/. C Agreed Upon Section rouernts Resolution study period (January-December, 1977) indicated an average dilution of 0.2 at a downstream distance of 2200 feet.
River flows during this period were typical of the average for the Missouri River for both the summer and winter months.
Plant operating capacity varied from 97%
to 34% of capacity with a monthly average of 75%.
Conservative evaluations of the measured data and other data from studies conducted from 1974 through '
1976 were used to develop emperical, predictive models to determine the maximum temperature within the plume as a function of downstrean distances to assure that tbc Environmental Technical Specification thermal limits were not exceeded.
These predictive models indicate a minimum addi-i tional dilution of the discharge of a factor of 2.5 for the summer months and a factor of 3.1 for j
the winter months within 1/4 mile.
Page 3 of 7 ODAM Fr u:
Agreed Upon Resolution Section
( en n ent :
A realistic evaluation of the water-fish-pathway should accommodate both dilution in the River and the mobi-lity of the fish and the fisherman.
Considering l
the mobility of the fish and fisherman, it seems likely that fish caught in the River near the Station would live in water averag-ing less than one-half of the mixed plume concentra-tion.
llence, it is esti-mated that fish caught in the River near the Station will have lived in water of which one-fifth or less passed through the dis-charge canal.
Since the nearest antici-pated withdrawal of water from the River for drink-l ing water or irrigation is l
at least 2 miles downstream j where water is diluted to less than one-fifth of canal discharge and since fish caught near the Sta-tion will have lived in water averaging one-fif th or less of canal discharge, a mixing ratio of five seems reasonable to use when evaluating the poten-
________________.__.__m._
Page 4 of 7 i
ODAM EGE.C Agreed Upon i
Section Comments Resolution tial dose to a person who l
may eat, fish, or drink water taken from the River i
near the Station.
In view l
of the Commission's advo-L cary or realism in models for evaluating ALARA envi-i ronmental doses, this seems !
justifiable, i
t
- Nebraska Public Power District, 1978, Demon-I stration of Compliance i
with 10 CFR 50, Appen-dix 1 Rev. 1,and j
Supp. 2. Jan. 9, 1978.
b Nalco, 1978, the Evalua-E tion of Thermal Effects in the Missouri River i
Near Cooper Nuclear Sta-tion, January-December, 1978.
i 2.5 State each target age group.
Section 2.5 is revised 2.5 State what pathways are examined and show all equations and The age group most ex-parameters used.
If a particular pathway is not examined, state posed via drinking water the reason, withdrawn from the Missouri River is expected to be the infant and the age group most exposed via eating fish taken from the
Page 5 of 7 ODAM H;t C Agreed Upon Section Comments Resolution i
River is expected to be the adult. Three other potential pathways of expo-sure to radiation or radio-active material in liquid effluent, namely deposition on the shoreline and ir-radiation of a person on the shoreline, irradiation.
of a swimmer, or irradia-tion of a boater, will not he calculated because pre-vious assessments, includ-ing one for Cooper Station" have shown that the dose to a person via these pathways is less than one-tenth of the dose via the critical pathway.
" Nebraska Public Power Distr'tet, 1978, Demon-stration of Compliance with 10 CFR Appendix 1, Rev. 1, and Supp. 2, Janua ry 9, 1978.
3.4 Will different X/Q value be used in the setpoint calculation for Section 3.4 is revised the vent and stack release for each sector.
4.2 A table of prevailing wind should be included.
It should show The ODAM is being revised wind rose factor and speed by sector for each season, and give (Appendix B) to include the X/Q factor.
reference meteorology
l ODAM i W. C Agreed Upon Section Conc 4 nt s Resolution tabulations of X/Q, de-pleted X/Q and D/Q for both elevated and ground-level releases in an Appendix B.
The reference meteorological measurements were made at Cooper Station during the period July 1, 1976, to June 30, 1977, and thus include a year of data.
Reference meteorological conditions are described in l
l summarv in Demonstration of Compliance with 10 CFR 50 l Appendix I, Revision I and Supplement 2, dated January 9, 1978, and sub-mitted to the NRC.
Compu-tation methods in the CDAM rely on X/Q, depleted X/Q, or D/Q factors to represent atmospheric dispersion and deposition. A supplemental wind rose and tabulations i
of wind speed would not be l
useful.
l l
(NPPD's own idea)
Delete Reference to C-14 on pg 13 Provide an assessment of doses to members of the public due to The only notable activity their activities inside the site beundaries. The dose calculations by members of the public shall be in accordance with the ODAM using meteorological conditions (excluding visitors and concurrent with the time of release, vendors) within the site boundary are boaters on
Page 7 of 7 (m/j t 1 (: <1 Agreed Upon Section n etents Resolution the Missouri River.
Some fishermen and some boateen use the river on a transient basis.
An estimate of their exposure potential can be derived from the product of radiation measurements on the east bank of the river and estimated expo-sure time.
Assuming a boater spends 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> per year (ref. Reg. Guide 1.109, Rev. 0) on the River near the Station, his direct exposure would in-crease by about one-fourth millirem annually. Given the low occupancy time expected of boaters in the River near the Station, their dose via direct radiation and inhalation pathways is expected to be much less than via cat-l ing fish caught in the River near the Station.
Estimation of dose to mem-bers of the public from exposure within the Sta-tion boundary will be based on the fish and (assumed) drinking water pathways because they are expected to contribute most of the exposure.