ML20062D384
| ML20062D384 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/04/1982 |
| From: | Serrano W EG&G, INC. |
| To: | Willis C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20062D360 | List: |
| References | |
| NUDOCS 8208060054 | |
| Download: ML20062D384 (34) | |
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Enclosure 1 e q U EGrG, ..
$4 . .
}; P.O. BOX 1625, IDAHO FALLS. IDAHO 83415 i
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May' 4, 1982 _.
i Mr. Charles A. Willis -
i Mail Stop P-730'
- Phillips Building s Effluent Treatment Systems Branch-
) U. S. Nuclear Regulatory Commission i Washington, D. C. 20555 4
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TRANSMITTAL 0F QUESTIONS FOR ARKANSAS RETS REVIEW - Serr-8-82 - .
Dear Mr. Willis:
Attached are lists of questions for ANO-1 and ANO-2 that will be dis-cussed with the Arkansas plant personnel regarding their RETS and 00CM submittals. However, there may be additional areas of discussion during the review with plant personnel. This letter supersedes any other previous correspondence.
Sincerel yours, W. Serrano -
Radiation Measurement Programs Branch '
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Attachment:
l As stated.-
P I cc: R. E. Ireland, NRC l J. Marshall, APL
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, 8208060054 820715 DR ADOCK 05000313 PDR 6
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RADIOLOGICAL EFFLUENT TE.. ..AL SPECIFICATIONS (RETS) REVIEW _
I. Purpose The purpose of this document is to provide the licensee with examples (i.e., prior to the in-plant review) of areas ,eere further clarificattan is required in the review of their RETS submittal and Off-Site Dose ~
~
Calculation Manual (00CM). Some of the areas addressed are such that full compliance with the model RETS is necessary, however, in many cases a justified alternative that meets the intent will be considered in compliance. This document is being submitted to the NRC plant manager prior to a complete internal review.
_ _ _ ,_ _ oN . NUREG 0472 Arkansas 1 Comments 1 The following definitions were not included in the proposed RETS. If they are used
- they should be included.
a Channel Calibration b Channel Check c Channel Functional Test d Dose Equivalent I-131 e Source Check f Process Control Program g Solidification h Offsite Oose Calculation Manual i Gaseous Radwaste Treatment System j Ventilation Exhaust Treatment System -
% Purge-Purging .
1 Venting -
2 Table Table The following frequencies were not included 1.2 4.27.2-1 in the submittal. If they are used, the symbol should be explained.
- 2a S at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
! 2b W at least once per 7 days l 2c SA at least once per 184 days ,
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'M. NUREG 0472 Arkansas 1 Conrents . __
3 3.3.3.9 3.5.6 Statements comparable to the following 3.3.3.10 3.5.7 action statements of the model RETS were not included in the submittal. ~
3a Action a ~~
3b Action b 3c Action c !
3d. ---
4.27.1.2 If these records are: identified in an 4.27.2.2 existing-record retention specification, then this statement could. be ~ removed.
4a. Tables Table. Arezall liquid:radwastes.. released:through-3.3-12' 3.5.6-1 the liquid radwaste effluent line?
4b Do the steam generator blowdown' effluents ~~
release through a monitored release point?
4c Are the turbine building floor drain effluents released through a monitored release point?
4d Do the monitor systems-for the~ preceeding releases have, automatic termination of release?
4e- Is the service water effluent' released through a monitored release point? .
4f Is the component cooling water released -
through a monitored release point? -
4g Are there continuous composite samplers and sampler flow monitors on the following systems:
- a. Steam generator blowdown line
- b. Turbine building sumps 4h Are there flow rate measurement devices on the following:
- a. Discharge canal
- b. Steam generator blowdown line 4i Are there radioactivity recorders with alarm / trip setpoints for radioactivity control?
4j Are there outside storage tanks requiring tank level indicators?
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- u- No. NUREG 0472 Arkansas 1 Comments '-
l 4k Action 28 Action A With less than the minimum number of i
liquid radwaste monitors operable,
! releases may continue for up to 14 days. m
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The proposal does not include a time ;
limit.
j j 41 Action 28 Action A If the conditions of action A cannot be met,
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, the model RETS requires that releases be suspended. The proposal does not include j this requirement.
4m Action 31 Action B With less than the number of liquid radwaste effluent flow rate devices operable,
- releases may continue for up to 30 days.
j i
The proposal does not contain a time limit.
Action 31 4n Action B It may be beneficial to state " Pump curves '*
may be used to estimate flow."
, 4o --- ---
Additional action statements will be required if other systems are identified that release directly to the unrestricted area.
Sa Table Table Surveillance checks are required on other
, 4.3-12 4.27.1-1 systems identified that release directly to the unrestricted area.
Sb The ** footnote on the source check for -
the radiation monitor requires discussion. .
Sc The channel calibration and channel test for the radiation monitor should be i footnoted.
I
! 5d The channel check for the flow monitor
- should be footnoted.
Se The following footnotes of the model RETS '
, were not addressed in the proposal:
- a. Footnote 1
- o. Footnote 2
- c. Footnote 3 1 d. Footnote 4 i
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- _ No. NUREG 0472 Arkansas 1 Commen s Table Table 3.3-13 3.5.7-1 6a Item 1 Item 1 Does the noble gas monitor in the waste gas $ ~
haldup system provide alarm and automatic
, termination of release? ]
6b Item l' Item l' The:following items-in the.wasteigas holdup system are listed.in the periodic check table.but not in-Table 3.5.7-1:
Iodine-sampler-a..
i b. . Particulate sarapler-
. c. Sampler-flow rate' measuring device
! 6c Item 1 Item 1 The gas activity monitor in the waste gas
- holdup system should be rperable at all
- i times in the event of an unplanned release.
l 6d Items 2A,2B --- Explosive gas monitors were not addressed in the proposal.
- a. Is the system designed to withstand an explosion?
- b. Is the. system operated in a hydrogen
(. rich condition?
l c. Are-there3 reliable hydrogen and/or -
! oxygen monitors? .
l d. Where are the monitors located?
l 6e Are the following systems released through monitored release points?
Item 3 --- a. Condenser evacuation system
- Item 4 --- b. Vent header system
( Item 8 --- c. Radwaste area ventilation system ,,
, Item 9 --- d. Steam generator blowdown vent system
?
f 6f Which effluents are released through the i main stack?
6g Item 5 Item 4 The following were not included for the reactor building purge system:
- a. Iodine sampler
- b. Particulate sampler 4
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No. NUR 3 0472 Arkansas 1 Comments
. 6h Item 5 Item 4 Does the gas activity monitor in the reactor building purge systen provide alarn and automatic termination of release? -
?
Si Item 6 Item 2 The following were not addressed for the ~~
auxiliary building vent system:
- a. Iodine sampler
- b. Particulate sampler 6j Item 7 Item 3 The following were not addressed for the spent fuel pool area:
- a. Iodine sampler
- b. Particulate samp.1er
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6k Action 35 Action A With less than the required number of gas monitors in the waste gas system, releases may continue for up to 14 days. The proposal does not contain a time limit.
61 Action 35 Action A If the conditions of action A cannot be satisfied, the model RETS requires that releases be suspended. The proposal does not include this requirement.
6m Action 36 Action B With less than the required number of flow rate monitors in the waste gas holdup system, releases may continue for up to ~
30 days. The proposal does not specify -
a time limit. -
. 6n ---
Action C Action C is attempting to address two i
action iteris of the model RET 5.
- 6o Action 37 Action C With less than the minimum number of gas
- monitors for the auxiliary or fuel storage buildings, releases may continue for up to 30 days provided grab samples are taken .
, every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The proposal does not
. limit the time for releases and proposes grab samples every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6p Action 38 Action C With less than the required number of monitors for the containment purge, the
- purging must be immediately suspended.
Sq Action 41 --- An action comparable to action 41 must be included for the iodine and particulate samplers.
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_ po. tik"Oi 0472 Arkansas 1 Catnments_ . : Y Table Table 4.3-13 4.27.2-1 7a Item 1 Item 1 A weekly channel check is required for the h iodine and particulate sampler instead of ~~
daily.
7b Item 1 Item;l The channel calibration and. channel
- l. functional tests should.berfootnoted.
7c --- -- - If other systems or' components are.
l identified, then' the periodic checks' must .
. be addressed.
7d Item 5 Item 4 A source check is required prior to each purge instead of monthly. .;
7e Item 5 Item 4 The channel calibration and channel Item 6 Item 2 functional test should be footnoted.
Item 7 Iten 3 The following footnotes listed in the model RETS were not addressed in the. proposal:
Footnote.1
' Footnote 2 Footnote.3 Footnote 4 l Footnote 5
]
8a 3.11.1.1 3.22-1 The applicability statement includes -
liquids released from the liquid radwaste -
system. Does this include all radioactive ,
liquids released to the unrestricted area? ,
l Sb ---
3.22.1.2 A prompt notification report is required !
instead of a 30-day notification when the '
concentrations released exceed the limits.
( 8c 4.11.1.1.2 ---
A post-release analyses of samples .,
l composited from batch releases is required. ;
l This was not adoressed in the proposal. '
8d 4.11.1.1.3 --- The radioactivity concentrations for
, continuous liquid releases was not e specifically addressed in the proposal. l l .
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No. NUREG 0472 Arkansas 1 Comments 3 i Table Table
- 4.11-1 4.24-1 9a Item A Item A The sampling frequency for the dissolved ;
j and entrained gases of prior to one batch
- . per month was cmitted.
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An analysis for Fe-55 is required from the quarterly composite sample at an LLD of 1 x 10-6 Ci/ml.
9b Item B ---
The sampling and analysis frequencies for the continuous releases were not addressed.
9c Footnote a Footnote a The at term is incorrect for both the liquid and gaseous systems. The at is the - -
elapsed time between midpoint of sample collection and time of counting for plant effluents. The LLD definition should state it is the "a priori" limit.
9d Footnotes ---
These footnotes address the continuous c and e releases and were not included.
9e Footnote d Footnote d The footnote should state the batch is isolated and tharcughly mixed prior to sampling.
10b Action a 3.22.2.2.b2 The action should also require a program to reduce the values to within the calendar quarter limits as well as the annual limits.
10c Action a 3.22.2.2.b3 The report is in lieu of the LER. This should be stated.
10d Action a 3.22.2.2.b3 The report must address effects on drinking water if applicaole.
10e 4.11.1.2 4.24.2.1 The cumulative dose calculation is to be made at least once per 31 days. This was not included in the proposal.
lla- 3.11.1.3 3.22.3.1 The equipment mu:t be operated when the orojected doses averaged over 31 days exceed certain values. The pecposal does not specifically state the projection require-ment and states calendar month instead of 31 days. .
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No. NUREG "A 2 Arkansas 1 Comments 11b 3.11.1.3 3.22.3.1 The doses in the proposal are a factor of four too large.
lic Action a 3.22.3.3 .
The special report, which is in lieu of the LER, is also to be submitted if the ~
equipment is inoperable for more than 31 days. The report should include the identification-of the inoperable equipment, reasons.for inoperabilit9 and actions to.
restore: the > equipment to operable status..
lld Action b. --- This statement should be included.
lie 4.11.1.3.1 --- The doses are to be projected in accordance with the 00CM at least once per 31 days.
~ ~
12 3.11.1.4 --- A specification for the curie content in the 4.11.1.4 liquid holdup tanks was not addressed.
13a 3.ll.2.lb 3.23.1.lb This specification should be reworded to i
state "For I-131, H-3 and particulates with half-lives greater than 8 days in the inhal~aticn pathway shall be i 1500 mrem /yr to any organ."
13b ---- 3.23.1.2 Does specification 6.12.3.2 require prompt notification reporting?
4.11.2.1.1 Both specifications should state the-13c 4.25.1.1 -
l 4.11.2.1.2 4.25.1.3 dose rates are to be determined in -
accordance with the ODCM. -
Table Table 4.11-2 4.25-1 14a Item A Item A H-3 analysis for the waste gas storage tank is not required. I-133 may be removed.
14b Item C Item C Monthly grab samples are required instead .'
of weekly.
l 14c Item 0 Item C A continuous sampler is required for all releases identified in Items A, 3 and C.
l 14d Item 0 Item C The gross alpha is to be analyzed from a i monthly comoosite particulate sample.
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l 14e Item D Item C An LLD of 1 x 10" uCi/ml is required for the noble gas (gross beta or gamma) monitor.
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No. NUREG 0472 Arkansas 1 Ccmments - Y l
14f Footnote b ---
A grab sample is to be taken from the --
, containment for analysis following startup, shutdown or a 15% rated thermal power -
change over a one hour period. 3 14g Footnote c Footnote c H-3 grab samples are to be taken at least ~~
~
once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of once per 7 days.
14h Footnote d ---
This footnote sas not addressed. It is concerned with the changeout of the charcoal and particulate samplers and increased sampling frequency following certain
. operational power changes.
141 Footnote e ---
H-3 grab samples are required every 7 days whenever spent fuel is in the spent fuel pool. ~~
14j Footnote g Footnote e Kr-87 was omitted.
15a 3.11.2.2 3.23.2.1.a Were noble gas releases from the turbine 3.23.2.2.a building (provided effluent sampling is not provided) and occupancy by the public within the site boundary taken into consideration when arriving at the dose limits. This shculd be stated in the 00CM.
15b Action a 3.23.2.2.b2 Corrective action should be taken to -
ensure the quarterly limits are not -
exceeded as well as the annual limits.
]
15c Action a 3.23.2.2.b3 The special report is in lieu of the LER i
, and should be stated.
1 i 15d Action b ---
This statement should be included.
15e 4.11.2.2 4.25.2.1 This surveillance specification is not j l completely clear to me. Does this mean ,,
l that once per quarter a dose calculation l will be made for batch releases? Cumuist4ve_
i doses-for~aLL_ releases are en ha made_at
! least-occe per-31 days -
15a 3.11.2.3 3.23.3.la These specifications should be reworded 3.23.3.2a as in 3.23.1.lb. Also these specifications are for the inhalation pathway only.
16b Action a 3.23.3.2b Typo in 3.23.2.2a. Should it be 3.23.3.2a?
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'lo . _ NUREG 0472 Arkansas 1 : n ents - Y 16c Action a 3.23.3.2.b2 The corrective action should be to reduce the release rates to within the quarterly as well as the annual limits. -
16d Action a 3.23.3.2.b3 The special report is in lieu of the LER and this should be stated. [ .
16e . Action b ---;
This specification should be included.
16f 4.11.2i3~ 4.25.3.1 This specification does not appear to meet i the intent of the model RETS requirements. l l Cumulativeedoses for all releases.are to ;
. be made monthly in accordance.with the 00CM.
I 17a 3.11.2.4 3.24.4 Typo: 3.24.4 should be 3.23.4 17b 3.11.2.4 3.23.4.1 The model RETS considers all gaseous ?l '
3.23.4.2 effluent releases. The proposal considers l
radiciodines and particulates or noble gases.
I 17c 3.11.2.4 3.23.4.1 The values stated in the proposal are a
~ ~ - - -
3.23.4.2 factor of four greater than the values in the model RETS. l 17d Action a 3.23.4.3 The special report (in lieu of the LER) is required if the equipment is inoperable for more than 31 days. j l
The report should include: -
l 1'
- a. Identification of the inoperable equipment and reasons for inoperability j i
- b. Actions to restore equipment to j<
l operable status j 1
i 17e Action b ---- The provisions.of-this specification should be included. ., .]
- 17f 4.11.2.4.1 --- The projected doses are required at least once per 31 days in accordance with the 00CM.
179 4.11.2.4.2 4.25.4 This specification should include the ventilation exhaust treatment system. j 18 3.11.2.5 --- A specification addressing the explcsive !
3.ll.2.5A gas issue was not included.
3.11.2.5B
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k' RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) REVIEW I. Purpose ,
The purpose of this document is to provide the licensee with examples ?
(i.e., prior to the in-plant review) of areas where further clarification -
is required in the review of their RETS submittal and Off-Site Dose -
Calculation Manual (00CM). Some of the areas addressed are such that full compliance with the model RETS is necessary, however, in many cases a justified alternative that meets the intent will be considered in compliance. This document is being submitted to the NRC plant manager prior to a complete internal review.
_,No. NUREG 0472 Arkansas 2 Comments 1 The following definitions were not included .
in the proposed RETS. If they are used they should be included.
a . Channel Calibration b Channel Check c Channel Functional Test d Dose Equivalent I-131 e Process Control Program f Solidification g Purge-Purging h Venting
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2 Table Table The frequency notations of table 1.2 were 1.2 4.27.2-1 not addressed in the submittal. If these -
~
frequency notations are used, they should be defined.
3 3.3.3.9 3.3.3.10.b The wording of this action requirement is more 3.3.3.10 3.3.3.9.b restrictive than required and may be changed to state "with less than the minimum number of radioactive liquid ...."
4.3.3.10.2 The tenn " MODES" as used in this specifi- ..'
4.3.3.9.2 cation is not defined nor is it readily apparent where it is used in Table 4.3-13.
- > ,) - 15 4a Table Table Are all liquid radwastes released through 3.3-12 3.3-13 the liquid radwaste effluent li.ne?
4b Do the steam generator blowdown effluents release through a monitored release point?
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.M c . NUREG 0472 Arkansas 2 Ccc. Tar.ts 4c Are the turbine building floor drain effluents released through a monitored release point? -
=
4d Do the monitor systems for the preceeding _,
releases have automatic termination of .
release?
4e. Is_ the service water-effluent released through a monitored release point?
4f' Is the component cooling ~ water released through a monitored; release point?'
49 Are there continuous composite samplers and sampler flow monitors on the following '
systems:
- a. Steam generator blowdown line
- b. Turbine building sumps 4h Are there. flow rate measurement devices on the-following:
- a. Discharge canal
- b. Steam generator blowdown line 41 Are there radioactivity recorders with alarm / trip setpoints for radioactivity -
control? .
4j Action 28 Action 18 With less than the minimum number of l
liquid radwaste monitors operable, releases may be resumed. The proposal does not include a 14 day time limit.
4k Action 28 Action 18.2 Does verifying the computer input data serve the same function as verifying the actual release rate calculation?'
41 Action 31 Action 19 With less than tne number of liquid radwaste effluent flow rate devices operable, i releases may continue for up to 30 days.
The proposal is more conservative than required by using a 14 day limit for releases.
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4m Action 31 Action 19 It may be beneficial to state " Pump curves may be used to estimate flow." -
4n Action 32 Action 20 The proposal does not include a 30 day time ?
limit for liquid additions to the tank with -.
less than the minimum number of channels .
4o --- ---
Additional action statements will be required if other systems are identified that release directly to the unrestricted area.
4p Action 31 Action 19 It may be beneficial to state " Pump curves may be used to estimate flow."
~
5 Table Tabl e Surveillance checks are required on other 4.3-12 4.3-13 systems identified that release directly to the unrestricted area.
Table Table 3.3-13 3.3-12 6a Item 1.a Item 1.a Does the noble gas monitor in the waste gas holdup system provide alarm and automatic termination of release?
6b Item 1 Item 1 The following items in the waste gas holdup system are not listed in table -
3.3-12.1.
~
- a. Iodine sampler
- b. Particulate sampler 6c Items 2A,2B ---
Explosive gas monitors were not addressed
, in the proposal.
i
- a. Is the system designed to withstand an explosion?
- b. Is the system operated in a hydrogen rich condition?
J i c. Are there reliable hydrogen and/or j oxygen monitors?
i i d. Where are the monitors located?
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- , . .. . v W. NUREG 0472 Arkaases 2 Ccren:s 6d Are the following systems released through monitored release points?
Item 3 ---
- a. Condenser evacuation system h Item 4 --- b. Vent header. system -
Item 9 --- c. Steam generator blowdown vent system ]
6e. Which effluents are released.through the main stack?
6f Item 5 Item 2 Does the: gas activity monitor in the-reactor building purge system provide alarm and automatic termination of' release?-
69 Action 35 Action 25 With less than the required number of gas monitors in the waste gas system, releases may continue for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The -
proposal is more conservative in the time requirement than required. They may substitute 14 days.
6h Action 35.2 Action 25.2 Does verifying the computer input, data serve =the same function as verifying the; actual release rate calculation?
6i Action 36 Action 26 With less than the required number of flow rate > monitors releases may continue for
. up to 30 days. The proposal does not specify a time limit. -
6j Action 37 Action 27 With less than the minimum number of gas 1 monitors releases may continue for up to 30 days provided grab samples are taken every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The proposal does not limit the time for releases and proposes grab samples every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6k Action 38 Action 27 With less than the required number of monitors for the containment purge, the purging must be immediately suspended. -.
61 Action 41 Applying Action 27 for the Containment Noble Gas Monitor is not as conservative as required by Action 38. The 30 day limit for continued release via this pathway with less than the minimum number of channels operable is not addressed.
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NUREG 0472 Arkansas 2 Comments Table Table 4.3-13 4.3-12 -
Item 1 Item 1 I 7a The iodine and particulate sampler was not addressed in the surveillance requirements.
7 7b Table Table Notation Notation 4.3-13 4.3-12 The specification for alarm annunciation 1&2 1&2 when instrument controls are not set in an operate mode was not addressed.
7c --- ---
If other systems or components are --
identified, then the periodic checks must
, be addressed.
7d The following footnotes listed in the model RETS were not addressed in the proposal:
Footnote 4 Footnote 5 8a 3.11.1.1 3.11.1.1 A prompt notification report is required instead of a LER notification when the concent:4tions released exceed the limits.
8b 4.11.1.1.2 ---
A post-release analyses of samples composited from batch releases is required. .
This was not addressed in the proposal.
8c ---
4.11.1.1.1 These specifications appear to be superfluous 4.11.1.1.2 and should be deleted.
. 4.11.1.1.4 4
Table Table 4.11-1 4.11-1 9a Item A Table 4.11-1 in the submittal is not very clear as to the sampling and analysis .,
frequency for batch releases. This needs to be discussed further for clarification.
An analysis for Fe-55 is required from the i quarterly composite sample at an LLD of i
1 x 10-6 Ci/ml.
j 9b Item B ---
The sampling and analysis frequencies, activity analysis, and LLO for the con-
! tinuous releases were not addressed.
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No. NUREG 0472 Arkansas 2 Comments 9c Footnote a Footnote a The at term is probably incorrect for both the liquid and gaseous systems. The at is the .
elapsed time between midpoint of sample .
collection and time of counting for plant '
effl uants. The LLD definition should state --
it is the "a priori" limit.
9d Footnotes Tliese footnotes address the continuous e and'e' releases and were not included.
9e+ Footnote d' Foot note > d ' The-footnote should.stateethe batch is isolated and thoroughly- mixed; prior. to sampl i ng.-
10a 3.11.1.2 3.11.1.2 The report is in lieu of the LER. This Action a Action a should be stated. -
10b Action a Action a The report must address effects on drinking water if applicable.
10c 4.11.1.2.1 4.11.1.2.1 What calculations for dose are being performed on continuous releases?
11a 3.11.1.3 3.11.1.3 The equipment must- be-operated when the:
3.11.1.3 projected doses averaged over 31 days exceed certain values. The proposal's values are not' a factor of - 4 too high. Also they state calendar month instead of 31 days. .
lib Action a 3.22.3.3 The special report, which is in lieu of ~
the LER, is also to be submitted if the equipment is inoperable for more than 31 days.
i lle 4.11.1.3.1 4.11.1.3.1 The doses are to be projected in accordance with the 00CM at least once per 31 days.
l 12 3.11.1.4 --- A specification for the curie content in the 4.11.1.4 liquid holdup tanks was not addressed. .,
13a 3.11. 2. l b 3.ll.2.lb This specification should be reworded to l 3.11.2.3 3.11.2.3 state "For I-131, H-3 and particulates with half-lives greater than 8 days.
13b ---
3.11.2.1 Does specification 6.9.1.9 require prompt l
notification reporting?
l 13c 4.11.2.1.1 This specification should state the 4.11.2.1.2 4.11.2.1.4 dose rates are to be determined in accordanca with the 00CM.
i 6
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__o._ NUREG 0472 N Arkansas 2 Coments Table Table l 4.11-2 4.11-2 14a Item A Item A H-3 analysis for the waste gas storage tank is not required. -
14b Table Tabl e The I-133 analysis requirement may be removed. ,
4.11-2 4.11-2 The only iodine analysis required is I-131.
1 14c Item D Item C The gross alpha is to be analyzed from a monthly composite particulate sample.
14d Item D Item D An LLD of 1 x 10-6 Ci/ml is required for the noble gas (gross beta or gamma) monitor.
14e Footnote b ---
A grab sample is to be taken from the containment for analysis following startup, shutdown or a 157. rated thermal power change over a one hour period.
14f Footnote c ---
H-3 grab samples are to be taken at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the refueling canal is flooded.
149 Footnote d ---
This footnote was not addressed. It is concerned with the changeout of the charcoal and particulate samplers and increased sampling frequency following certain 1-operational power changes. ,
14h Footnote e ---
H-3 grab samples are required every 7 days whenever spent fuel is in the spent fuel pool. i i
15a 3.11.2.2 3.11.2.2 Were noble gas releases from the turbine building (provided effluent sampling is (
not provided) and occupancy by the public I within the site boundary taken into .j consideration when arriving at the dose limits. This should be stated in the ODCM.
15b Action a Action a The special report is in lieu of the LER and should be stated.
16a 3.11.2.3 3.11.2.3 The special report is in lieu of the LER Action a Action a and this should be stated.
l 17a 3.11.2.4 3.11.2.4 The dose values stated in the proposal are a
! factor of four greater than the values in the model RETS.
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2 No.- NUREG 0472 Arkansas 2 Comments 17b Action a Action a The special report (in lieu of the LER) is required if the equipment is inoperable ,
for more than 31 days. ,
17c 4.11.2.4.1 ---
The projected doses are required at least once per 31 days in accordance with the ODCM.
18 3.11.2.5' --- A' specification addressing the explosive 3.ll.2.5A. gas. issue.was'not included 3.I1.2.58.
19a 4.11.2.6 4.11.2.7 The model RETS requires the quantity of radioactive material to be determined at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. .
20 3.11.3 ---
A specification addressing the solid radio-active waste system was not included.
21 3.11.4 ---
A specification addressing the total dose was not included.
3.12. - - - This specification is not addressed in this submittal but they state they will use the same requirements as ANO-1..
22 Bases Bases The word "not" in the sixth line:of this, 3/4.11.1.1 3/4.11.1.1 specification should be-removed.
~
23 Bases Bases The submittal should include section II C 3/4.11.2.4 3/4.11.2.4 of Appendix I to 10 CFR in the last line of this bases statement.
24a 6.5.1.6 --- Is the Plant Safety Committee comparable to the Unit Review Group described in the model RETS?
i 24b 6.5.1.6 -- -
The Unit Review Group must review changes ,
l to:
- b. Radwaste Treatment Systems l
25a 6.5.2.8 6.5.2.8 Is the Safety Review Committee comparable to the Company Nuclear Review and Audit Group defined in the model RETS?
25b 6.5.2.8 ---
The CNRAG shall audit:
- a. The radiological environmental program every 12 months.
l 8
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, ,c i1 .,2 No. NUREG 0472' Arkansas ~2 Comments
~*
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. b. The process control program and procedures every 24 months
- c. The Quality Assurance program every ~
12 months 26 6.8.1 6.8.1 Procedures are required for:
- a. The PCP
- b. The QA program 27 6.9.1.6 The Annual Radiological Environmental Operating 6.9.1.7 Report was not addressed.
28a 6.9.1.9 6.9.1.11 The model RETS references Reg. Guide 1.21 Rev. 1 Appendix B. The proposal references Reg. Guide 121, Rev. O Appendix A.
28b 6.9.1.9 6.9.1.11 The releases reported should be on a quarterly basis.
The following should be in the semi-annual report:
28c a. Meteorological data 28d b. Assessment of radiation doses during the previous calendar year 28e c. Doses to members of the public due to their activities inside the site boundary -
28f d. Demonstration of compliance with 40 CFR 190
\
28g e. Summary of solid waste shipped off-site l 28h f. Changes to the PCP 29 6.9.1.10 Changes to the ODCM can be reported in the '
semi-annual report'instead of the monthly report.
30 6.9.1.13 --- This specification was not addressed.
- 31 6.10.2 ---
Records to be retained for the radiological
' environmental monitoring program must be identified.
I 32 6.13 --- A specification for the PCP was not included.
Although Hittman Nuclear is subcontracted for waste solidification, a PCP must be addressed.
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No. NUREG 0472- Arkansas 2 Comments 33a 6.14 6.13 Changes to the ODCM can be reported in the semi-annual report. ,
33b 6.14.1 6.13 The ODCM requires NRC approval prior to ?
impl ementation. This should be stated in -
the specification. -
33c 6.14.2c 6.13.2 Documentation of the fact that the changes l were reviewed and:found acceptable;by the-group equivalent to the'URG is required, i 34 6.151 -- Aispecification addressing: major-changes-to -
thesradwaste. treatment' system was not-included. Although any major change would be considered an unreviewed safety issue and would be addressed through 10 CFR 50.59, .
the information requested in 6.15 is required by the NRC.
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No. NUREG cr 2 Arkansas 1 Comments 5 19a 3.11.2.6 3.23.5 Action b of the model RETS should be included.
19b 4.11.2.6 4.25.5 -
How often is the quantity of radioactive h material determined. The model RETS requires at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. I 20 3.11.3 ---
A specification addressing the solid radio-active waste system was not included.
21 3.11.4 ---
A specification addressing the total dose was net included.
22a 3.12.1 4.26.1 The special report is in lieu of the LER.-
This should be stated.
22b Action b 4.26.1.2.b The special report is required if:
~
3, g concentration reporting level )isotcpe > 1.0
- b. When radionuclides other than those in Table 4.26-3 are detected and if the calendar year limits are exceeded.
22c Action d ---
This specification should be included.
Table -
Table
)
3.12-1 4.26-1 23a Airborne Only five locations are required. Seven are proposed.
23b Direct Forty TLD locations with 2 dosimeters Radiation per location are required. Only seven locations are proposed.
23c Waterborne The surface water sample is to be a Surface composite frcm aliquots at two-hour ..
intervals for < 31 days.
23d Drinking The sampling and collaction frequency is inadequate.
23e Drinking Three sample locations are required.
One is proposed.
23f Sediment Only one sample location is required.
Two are proposed.
11
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NUREC ^!
No. ? Arkansas 1 Comments- ..
23g Milk The samples are to be collected at least once every 15 days when animals are on pasture. The proposal states 31 days. -
The 31-day collection period is when the e animals are not on pasture. ~
24 Table Table The reporting level for H-3 is 30,000 3.12-21 4.26-3 instead of 20,000 pCi/1. This reporting level is for drinking, water. samples -(a 40'CFR 191 value).
25a. Tabl e' Table- The-LLD for I-131 in water-is a drinking:
4.12-1 4.26-2' water value.
25b The values in the tables are not in complete agreement. ,
25c Footnote a Footnote a The words "a priori" should be included in the LLD definition.
25d Footnote c ---
A footnote stating other radionuclides if identified will be reported should be.
included; 26a 3;12.2' 4.26.2.1 Are there elevated releases that would require additional information in the land use census?
i 26b 3.12.2 4.26.2.1 Are the reactor buildings for both units' ~
in close proximity?
26c Action a,b 4.26.2.3a,b The special report is in lieu of the LER.
26d Action b 4.26.2.3.b The locations n: d be added only if the doses are >20% or' the dose from an existing location.
26e Action c --- This provision should be included.
27 3.12.3 4.26.3 This provision should be included.
28a 6.5.1.6 --- Is the Plant Safety Committee comparable to the Unit Review Group described in the model RETS?
28b 6.5.1.6 ---
The Unit Review Group must review changes l to:
1
- b. Radwaste Treatment Systems l
12 l
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No. NUREG 0472 Arkansas 1 Comments 29a 6.5.2.8 6.5.2.1 Is the Safety Review Group comparable to the Company Nuclear Review and Audit Group defined in the model RETS? -
29b 6.5.2.8 ---
The CNRAG shall audit:
- a. The process control program and procedures every /4 months
- b. The Quality Assurance program every 12 months 30 6.8.1 6.8.1 Procedures are required for:
- a. The PCP
- b. The QA program _
31a 6.9.1.7 6.12.2.4 The last paragraph repeats the land use census reporting requirement.
31 b 6.9.1.7 6.12.2.4 The
- footnote should be changed since changes are to be reported in the semi-annual report.
32a 6.9.1.9 6.12.2.5b The model RETS references Reg. Guide 1.21 Rev. 1 Appendix B. The proposal references Reg. Guide 121, Rev. O Appendix A.
32b 6.9.1.9 6.12.2.5c The releases reported should be on a -
quarterly basis. -
6.9.1.9 6.12.2.5 The following should be in the semi-annual report:
32c a. Meteorological data 32d b. Assessment of radiation doses during the previous calendar year 32e c. Ooses to members of the public due to their activities inside the site boundary 32f d. Demonstration of compliance with 40 CFR 190 32g e. Summary of solid waste shipped off-site 32h f. Changes to the PCP 13
No.. NUREG C4'? , Arkansas 1 Commentf : __
33 6,9.1.10 6.12.2.3- Changes to the ODCM can be reported in the semi-annual report instead of the monthly report.
34 6.9.1.13 ---
Are the reports on page 145 30-Day Written #
Reports? --
35- 6.10.2 ---
Records to be retained for the radiological environmental monitoring program must be identified.
36 6.13 ----
A specification;for the PCP was not included. ,
Although Hittman Nuclear is subcontracted i for waste, solidification, a PCP must-be -'
addressed.
37a 6.14 6.13 Changes to the 00CM can be reported in the ..
semi-annual report.
37b 6.14.1 6.13.1 The ODCM requires NRC approval prior to ,
impl ementation. This should be stated in the specification. ;
i 37c 6.14.2c 6.13'.2 Documentation of the fact that the changes 'I were reviewed and found acceptable by the group f equivalent to the URG is required. t i
38 6.15 ---
A specification addressing' major changes to i the radwaste. treatment system was not ';
included. Although any major change would be considered an unreviewed safety issue
- and would be addressed through 10 CFR 50.59, the information requested in 6.15 is required ]
i by the NRC. j H
14 i
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ARKANSAS NUCLEAR ONE 00CM RE7IEW E'
00CM Sections Comments __
2.2.1 List the values for BF 7and DFy . h
! 3.2.1 How was the value for (T/U), obtained? Is this an annual average or a more conservative value?
1 ,
3.2.2 How was the dispersion parameter, W, obtained?
Equation (7) - Define 3.17 x 107 .
- Equation (8) - Define 1.73 x 10 5 and 5.73 x 10-7 .
List the values for DFA9 , F 9, and DFL9 .
]
3.4.2 Some of the parameters used in the pathway analysis, such as f pand f are s not identified.
Table 4-1 The table should also contain the type of samples collected, i the type of environmental radiation measurement made, and the i frequency of sampling and measurement. j There should also be a table of milk forms or pasture locations, ,,
wind rose factor and annual average X/Q by sector.
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. Enclosure 2 ,
j ACTIONS, COMMENTS AND METHOD OF RESOLUTION RELATED TO EACH SPECIFIC QUESTION OF
- ENCLOSURE 1 FOR AN0-1 1 1. AP&L will include appropriate definitions, revise woYding ~of deffnf tions as ~
- appropriate. "' ~ ~~
~
- 2. Frequencies i 2a. S - AN0-1, S=8 hr.
ANO-2, S=12 hr.
AP&L will consider changing ANO-1 to 12 hr.
- 2b. W-AP&L will include weekly frequency.
2c. SA-AP&L will consider a semi-annual frequency.
4 3a. Action a - AP&L will include 3b. Action b - AP&L will include 4
3c. Action c - AP&L will check if 3.0.3 and 3.0.4 are applicable and will include j the LER exception.
3d. AP&L will respond to this item 4a. Yes 4b. No-Once through steam generator, No blowdown 4c. No-not by instrumentation-by grab sample only if there is primary to secondary -
leakage. Procedures require turbine building sump be pumped to waste -
neutralizing tank if there is primary to secondary leakage. Neutralizing tank is isolated in this case.
4d. AP&L will provide automatic temination of release 4e. Reactor Bldg. Air Coolers and Decay Heat Coolers have monitors. These will be added to the table with appropriate surveillance requirements. AP&L will check for other pathway of releases.
l 4f. Component cooling water system is a closed system. The pressure is less than SW pressure. CCW is released only if drained during an outage 4g. a. No b. No 4h. a. No: detemine flow by number of circulating pumps operating b. No
- 41. No 4j. Na OH and BWST tanks do not have level indicator, are Tech Spec elsewhere 4k. Not applicable l 41. AP&L will include the statement 4m. Not Applicable
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4n. AP&L will add statement. -
k 40. AP&L will consider additional ~ action statements for recorders, neutralizer ?
I tank, turbine b1dg., sump etc. -.
Sa. AP&L will consider other surveillance checks.
Sb. AP&L will reword footnote.
, Sc. AP&L will insert appropriate-footnote and: statement.
5d;. This is acceptable *as is'..
5e. AP&L will add what is needed.
6a. Yes '
6b. These items will be removed frvm the surveillance table since they do not exist.
i 6c. No problem - Stack monitor will catch the release.
6d. This item is being handled as a separate issue. AP&L has comitted to monitor and will' submit a TS change.
6e. d. thru . c. -Yes - d..no release point 6f. The.re are actijailyIfour. rel' ease points and the four are . listed. in the table. -
~
6.
~
9 The iodine and[ particulate s'ampilers are ' existing and Vill be included.. , 2 6h. No - cannot purge during power operation.
l 61. This will be included, i
6j . This will be included.
j 6k. Not applicable.
- 61. This will be included.
l 6m. Not applicable.
l 6n. ANO-1 does not have a containment purge monitor. It is a containment ventilation monitor. Purge is governed by a feed and bleed operation.
- 60. AP&L will change grab sample to every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
6p. Not applicable.
6q. AP&L will add this action statement with modification.
7a. AP&L will change to weekly.
l 7b. AP&L will change as in liquid systems.
l
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Enclos.ure 2 ._____ l ~T _ ._.
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i 7c. Iodine and particulate samples will be addressed.
f' ' ' ' ' ' "7d. ' purging This will be If AP&L provides a new and better method of this .left as is.
then the monitor may become a purge monitor which would require
~~' ~';
procedure checksC ~ ~ ~ ~ ~
7e. Same as 7b. above - will be included.
8a. AP&L will change to be more general to cover all release points at all times .
8b. AP&L will change to prompt notification.
8c. AP&L will remove 4.24.1.1 & 4.24.1.2 since 4.24.1.3 covers all .
8d. No - there are no continuous releases.
9a. AP&L will leave as is. EG&G will provide AP&L with a procedure for Fe-SS. ~ #~
9b. Not applicable.
9c. AP&L will correct the AT definition.
10b. 3.22.2.2.b.2 should read 3.22.2.la & 2a 10c. AP&L will omit the LER reuqirement.
10d. Receiving water is r.ot a drinking water source - too salty.
10e. AP&L will include the word "at least monthly".
lla. AP&L will remove " appears that" and replace with " projected". .
lib. AP&L will change limit to 0.02.
lic. Report will be an operating report - not an LER, lid. AP&L will include statement if needed. 4.24.3 will be removed.
l Ile. AP&L will as a qualifying statement th at the projections are not required l if equipment is operating at all times. ,
- 12. AP&L will include specifications for curie content in holdup tanks except for Na OH and BWST tanks.
! 13a. The specification will be reworded as suggested.
l l
13b. Will change to prompt notification.
l 13e. Both specifications will state the dose rates to be determined in accor-l dance with the ODCM.
14a. AP&L will delete H-3 and I-131 analysis.
14b. Monthly grab samples will be required.
l 14c. AP&L will include Reactor Bldg. ventilation, y
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Enclosure 2
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f 14d. EG&G will provide AP&L with a procedure and AP&L will consider the -
surveillance.
l 14e. AP&L will include as X e-133 equivalent unless the LLD is a problem with [
other equipment.
! 14f. AP&L is. reluctant to include this. requirement. They will consider using
' the failed fuel monitor-for an increase of' activity every 4 hrs. .by a factor of 3. Also will look at the stack monitor for an increase of activity by a factor of-3 every-4 hours..
14g. AP&L will add:the footnote.
) 14h. AP&L will add a footnote similar to words as 14f. above.
~
4 141. AP&L will include grab sample of H-3 onspent fuel pool vent.
. 14j. AP&L will include K -07*
r 15a. Not applicable.
- 15b. AP&L will do this.
15c. AP&L will' provide special report in lieu of LER.
15d. AP&L will~ consider statement.
15e.. Acceptable as is. '
16a. This will be corrected.
- 16b. The typo will be corrected.
16c. AP&L will correct this as appropriate.
16d. A special report will be provided in lieu of LER.
16e. AP&L will correct this.
16f. Acceptable as is.
17a. AP&L will correct.
17b. Acceptable as is.
17c. AP&L will correct values.
17d. A special report will be provided in lieu of LER.
17e. AP&L will consider this specification.
17f. AP&L will include this.
179 . AP&L will remove this.
k 3
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Enclosure 2 _
5
- 18. This is being handled as a separate issue.
i 19a. AP&L will reevaluate this limit. They will consider 24 hr. sampling .
when have 1% failed fuel.
19b. AP&L will consider this. -
I
- 20. AP&L will include as worded.
- 21. ' AP&L will include this specification.
22a. A special report will be provided in lieu of a LER.
l 22b. AP&L will include these provisions.
22c. AP&L will include this specification. No report is needed concerning 4.26.1.2c.
23a. AP&L will leave as is.
23b. 40 TLD locations will be specified.
l 23c. AP&L will sample the intake weekly, the output daily, once monthly at other points.
23d. This doesn't need to be in the table t.ince drinking water doesn't come from the river.
23e. Same as 23d.
23f. AP&L will provide one sample location. -
l 23g. AP&L would like to depend upon the state obtaining milk samples. The i farmers do not want to be bothered by several agencies collecting milk j samples, i
- 24. What AP&L has proposed is acceptable.
i 25a. Same as 24. I l
25b. AP&L will add the LLD for sediment.
25c. AP&L will add the footnote.
25d. AP&L will add the footnote.
- 26a. Na 26b. No 26c. A special report will be specified in lieu of a LER.
26d. AP&L will change only if doses are > 20% of the dose from existing locations.
26e. AP&L will include this provision.
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n Enclosure 2 27. This is acceptable as is. -
28a. Yes. -.
~
29a. Yes-29b. a. AP&Lwill add,the PCP requirement b. AP&L-will add the QA audit &-
reference 1.21 & possibly 4.1
- 30. AP&L will resolve this' issue?
31a. This will be removed.
31b. This will be removed.
32a. AP&L will change as appropriate.
32b. This is acceptable as is.
~
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32c-h. . This is acceptable as is.
- 3. This is acceptable as is.
34 Yes-acceptable as is.
- 35. AP&L will add'this provision.
- 37a. AP&L will change as appropriate.
37b. Not applicable.
37c. Acceptable as is.
- 38. Not applicable. ,.
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- Enclosure 2- -s
.c .
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~ ~ ._ FOR ANO-2 ,
E
- 1. AP&L will add appropriate definitions.
i 2. Same as for Unit No.1.
- 3. AP&L will change words and correct term " mode". -
4a. Yes [
4b. There is a blowdown but it is a closed system.
4c. Yes-at gross monitor at discharge point.
4d. Same as for Unit No.1.
4e.
4f. " " " " "
4g. a. No b. No 4h. a. They use the number of pumps as the measure
- b. Not applicable since it is a closed system.
4i. No 4j. Not applicable.
4k. Acceptable as is.
- 41. AP&L will remove reference to 14 day limit. ,
4m. AP&L will include this. .,
4n. This concern goes away - not applicable.
- 40. AP&L will consider this issue.
- 5. This is acceptable.
l 6a. AP&L will add words of explanation.
6b. This is acceptable.
6c. This is being handled as a separate issue.
6d. Yes, Yes, Yes.
6e. Not applicable.
t 6f. Same as for ANO-1.
6g. Not applicable - AP&L will remove 72 hr. condition.
6h. Yes I
- 61. Acceptable as is.
6j. AP&L will change grab sample from 24 to 12 hrs.
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Enclosure 2 FOR ANO-2 6k. This is acceptable.
- 61. This is not applicable. .*
7a. Same as for Unit No. 1. [
7b. AP&L will actually state.what they have.
7c. This is acceptable..
7d. AP&Lwill address the footnotes. . ,
8a. A special report will be provided in lieu of^a LER.
8b. This is covered in 4.11.1.1.3. j 8c. AP&L will remove 4.11.1.1.1, 4.11.1.1.2, 4.11.1.1.4 & 4.11.1.1.5. i 9a. AP&L will clean up table & include Fe-55.
i 9b. Not applicable.
9c.. Same as for Unit No.1. ;
9d. Not applicable.
9e. Acceptable as. is.
lua. AP&L will change this as appropriate. .
=
106. Not applicable.
10c.
lla. AP&L will change as for same as Unit No.1.
lib. A special report will be provided in lieu of a LER.
lic. AP&L..will add ODCM'and also state that the jection is required if. _
equipment is used all the time, 4.11.l.3.2 1 be~ dropped. _
]
13c. Same as for Unit No.1. AP&L will remove 4.11.2.1.2.
14a. AP&L will remove this provision.
14b. AP&L will mmove referenced provision.
i 14c. EG&G will provide procedure - AP&L will resolve this issue, 14d. AP&L will include this.
j 14e. Same as for Unit No. 1.
a .- --
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Enclosure 2 FOR ANO-2 14f. AP&L will add this and state if it applies to reactor building only. 1) i 14g. AP&L will include footnote but with modifications. ~~~
14h. AP&L will add footnote to specify every 7 days.
15a. Not applicable.
15b. AP&L will make the change.
- 16. Special report will be provided in lieu of LER.
17a. AP&L will reduce the specified dose values. 3.11.2.3 will be consistent with Unit No. I and will include an annual limit. -
17b. Not applicable.
17c. AP&L will add the dose projection requirement.
18.__ This is being handled as a separate issue.
19a. AP&L will change this to every 24 hrs after a trigger limit of 1% fuel failure is reached.
- 20. AP&L will add a specification for a solid radioactive waste system.
- 21. AP&L will include a total dose. value.
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- 22. AP&L will correct wording. *
- 23. Not applicable.
ODCM 3.2.1 AP&L wants to use a Y/Q based on real time values.
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_ , . ? , ., ' ;Enclosure 2 .
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n AITENDANCE LIST FOR APPENDIX I REVIEW-MEETIflG ON ANO-1 & 2 ---JUNE:22,1982, _ . . ._ __
Guy S. Vissing Dennis Taylor Stephen W. Duce
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Blaine Murray John R. Marshall Bill Serrano -
Charles Nichols David D.. Snellings' W. D. Johnson Randy Pool L. J. Callan Gary. Fiser--
Alan Cox B. Baker (ExitMeetingOnly) .
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