ML20062N131

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Proposed ETS Sections 2.4.2,2.2.2 & 3.2.2 Re Annual Environ Operating Repts
ML20062N131
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 12/01/1981
From:
ARKANSAS POWER & LIGHT CO.
To:
Shared Package
ML20062N104 List:
References
NUDOCS 8112180421
Download: ML20062N131 (6)
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ANO-1 BASIS FOR CHANGE. t Section 2.4.2 Amendment 37 modified Section 5.6.1 in such a way that radiological effluent reports were no longer included in the Environmental Operating Report and the Environmental Operating Report was changed from semi-annual to annual. The amendment failed to change Section 2.4.2 which required radiological gaseous effluent reporting in the report re ., aired by Section 5.6.1. The radiological _ effluent reports still have to be submitted semi-annually as a result of the requirements of 10CFR50.36a and subsequent to Amendment 37 have been submitted separately '

from the Annual Environmental Operating Report on a semi-annual frequency. This creates a situation where a technical violation of Section 2.4.2 occurs every time an Annual Environmental Operating Report is submitted without the radiological effluent' report. This change corrects this situation by referring to 10CFR50.36a instead of Section 5.6.1.

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2-14 Monitoring Requirement

1. Radioactive gaseous waste sampling and analysis shall be performed in accordance with Table 2-2.
2. All waste gas monitors shall be calibrated at least quarterly by means of a known radioactive source. Each monitor shall have an instrument channel test at least monthly and when discharging checked at least daily.
3. During power operation, the condenser vacuum pump discharge shall be continuously monitored for gross radiogas activity. The monitor shall not be inoperable for more than 7 days. Whenever this monitor is inoperable, grab samples shall be taken and analyzed for gross radioactivity daily.
4. Records shall be maintained and reports of the sampling and analysis results shall be submitted in accordance with 10CFRSC.36a.
5. The Waste Gas Decay Tank effluent monitor shall be tested prior to any release of radioactive gas from a decay tank and shall be calibrated at refueling intervals.

Bases:

It is expected that the releases of radioactive materials and gaseous wastes will be kept within the design objective levels and will not exceed on an instantaneous basis the dose rate limits specified in 10CFR20.

These levels provide reasonable assurance that the resulting annual exposure from noble gases to the whole body or any organ on an individual will not exceed 10 mrem per year. At the same time tha Licensee is permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power under unusual operating conditions which may temporarily result in releases higher than the design objective levels but still within the concentration limits specified in 10CFR20. It is expected that using this operational flexibility under unusual operating conditions, the Licensee shall exert every effort to keep levels of radioactive materials and gaseous wastes as low as practicable and that annual releases will not exceed a small fraction of the annual average concentration limits specified in 10CFR20. These efforts shall include consideration of meterological conditions during releases.

ANO-2 BASIS FOR CHANGE Section 2.2.2 Previous changes to the draft Environmental Technical Specification (ETS) l changed Section 5.6 in such a way that radiological effluent reports were no longer included in the Environmental Operating Report and the-Environmental Operating Report was changed from semi-annual to annual.

The changes failed to change Section 2.2.2 which required radiological gaseous effluent reporting in the report required by Section 5.6. The radiological effluent reports still have to be submitted semi-annually as a result of the requirements of 10CFR50.36a and are submitted. separately from the Annual Environmental Operating Report on a semi-annual frequency. This creates a situation where a technical violation of Section 2.2.2 occurs every time an Annual Environmental _ Operating Report is submitted without the radiological effluent report. 'This change corrects this situation by referring to 10CFR50.36a instead of Section-5.6

3. During power operation, the condenser vacuum pump discharge shall be continuously monitored for gross.

radiogas activity. The monitor shall not be inoperable for more than 7 days. Whenever this monitor is inoperable, grab samples shall be taken and analyzed for gross (p, y) radioactivity daily.

4. Records shall be maintained and reports of_the sampling and analysis.results shall be submitted in accordance with 10CFR50.36a.
5. The Waste Gas Decay Tank effluent monitor-shall be tested prior to any release of radioactive gas from a decay tank and shall be calibrated at least once every 18 months.

Bases:

It is expected that the releases of radioactive materials and gaseous wastes will be kept withir, the design objective levels and will not exceed on an instantaneous basis the dose rate limits specified in 10CFR20.

These levels provide reasonable assurance that the resulting annual exposure from noble gases to the whole body or any -

organ of an individual will not exceed 10 mrem per year. At that same time the Licensee is permitted the flexibility of j operation, compatible with considerations'of health'and i- safety, to assure that the public is provided a dependable 4

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ANO-2 BASIS FOR CHANGE Section 3.2.2 The existing Section 3.2.2 requires an estimation of types, amounts, duration and timing of chemical discharges from ANO-2. It also requires that this information be tabulated, compared to Final Environmental Statement and Table 3.6, reported and maintained. The capability to make such estimates does not exist at ANO. As a result, all Annual Environmental Operating Reports are inconsistent with the Environmental Technical Specifications. This' change makes the ANO-2. requirement consistent with the ANO-1 requirement by keying on chemical usage rather than chemical discharge.

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Replace Existing 3.2.2 With The Following 3.2.2 Chemical Usage Inventory To assure that changes in the use of chemicals to treat plant water systems are preceded by consideration of environmental impact, the use of chemicals other than biocides to treat plant water systems of ANO Unit-2 shell be restricted to those chemicals listed in Table 3-1.

Short term and annual use rates shall not exceed the limits in the table by more than a factor of 3.0. Records of actual chemical usage shall be maintained and summarized by month in reports filed under Specification 5.6.1.

If actual short-term or annual use rate exceeds the values in Table 3-1 by more than a factor of 3.0 or if other chemicals must be used, environmental effects of such chemical usage, the expected release concentration and the duration of use shall be reported in accordance with Specification 5.6.2.b.

Table 3-1 Chemical Usage Lbs. Description of Use Chemical Formula Annual Monthly Sulfuric Acid HpS04 1,000,000 Make up Water DI 83,333 Startup Blowdown DI Sulfuric Acid H SO 2 4 4,800,000 Cooling Tower 400,000 Sodium Hydroxide Na0H 1,400,000 Make up Water DI 116,666 Startup Blowdown DI Ammonium Hyaroxide NH 0H 250,000 Secondary System 4

20,833 pH Control Hydrazine NH 60,000 Secondary System 24 5,000 0xygen Control Sodium Nitrite nan 0 2

4,800 Closed Loop 400 Water Systems Detergents 3,000 Laundry 250 Boron p 200,000 Reactor Coolant 16,666 System Lithium Hydroxide LiOH 755 Reactor Coolant 65 System Total Corrosion 396,000 Cooling Tower Inhibitors, Deposit 33,000 Inhibitors and Dis-persants

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