ML20063N332

Forwards Final Draft Radiological Effluent Tech Specs, Offsite Dose Calculation Manual & Justifications for Deviation from Revision 3 of NUREG-0472.Details of Process Control Program Will Be Available in Approx 4 Wks

ML20063N332
Person / Time
Site:	North Anna
Issue date:	09/16/1982
From:	Smith E VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Engle L NRC
Shared Package
ML20063N333	List: ML20063N332 ML20063N338 ML20063N339
References
RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 8209200213
Download: ML20063N332 (6)

Text

I PCO VIRGINIA ELECTRIC AND POWER COMPANY Mr. Leon B. Engle Richmond, Virginia U. S. Nuclear Regulatory Commission Washington, D. C. 20555 September 16, 1982

Dear Mr. Engle:

y u -- t h 7 i

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS AND OFFSITE DOSE CALCUI ATION MANUAL Enclosed, in Attachments I and 2 respectively, are the final draft copies of the North Anna Units 1 and 2 Radiological Effluent Technical Specifications (RETS) and Offsite Dose Calculation Manual (ODCM). Also enclosed, as Attachment 3, are the justifications f rom deviating f rom Revision 3 of the Radiological Effluent Technical Specifications (NUREG-0472).

Vepco is currently looking into a Process Control Program for North Anna Power ,.i Station. The details of a Process Control Program will be available in approximately 4 weeks.

This information is in final draf t form. It must be reviewed by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control staff prior to final submittal to the Nuclear Regulatory. Commission.

Copies of this information have also been sent to Mr. Andrew Cassell of the Franklin Research Center.

If you have any questions, please do not hesitate to call.

Very truly yours, E. R. Smith, Jr.

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0 07 Attachments cc: Mr. Andrew Cassell Franklin Research Center Philadelphia, Pa. 19103 8209200213 820916 PDR ADOCK 05000338 P PDR

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ATTACHMENT 3 JUSTIFICATIONS FROM DEVIATING FROM NUREG-0472 REVISION 3

The definition of the Process Control Program (PCP) is still pending in Vepco's review. This is because North Anna Power Station does not have a PCP.

Various vendors are being contacted to see what can be offered and the availability. Vepco will submit a definition for the PCP in approximately 4 weeks.

In Table 3.3-12, the Steam Generator Blowdown Effluent Line and the Turbine Building Sumps Effluent Line are not included because they are not release points for: (1) gross radioactivity monitors providing alarm and automatic termination of release, (2) gross beta " gamma radioactivity monitors providing alarm but not providing automatic termination of release. (3) continuous compcsite samplers and sampler flow monitors, and (4) flow rate measuring devices. The only, release point for continuous composite samplers and sampler flow rate monitors is on the Clarifier Effluent Line. The Discharge Tunnel is not included because it is not a release point. There are currently no radioactivity recorders on the Liquid Radwaste Effluent Line and the Steam Generator Blowdown Effluent Line at North Anna.

Action 28, in Table 3.3-12 of NUREG-0472, Revision 3, has been deleted because it pertains to batch releases and the Liquid Radwaste Effluent Line has a continuous release. Action 29, of NUREG-0472 Revision 3, has been deleted because the Steam Generator Blowdown Effluent Line has been deleted as a separate release point. All action statements have been renumbered so they are numbered sequentially in the Technical Specifications.

Table 4.3-12 has been revised to be consistant with Table 3.3-12. Table notation 3, of NUREG-0472, Revision 3, is deleted because North Anna 1 and 2 are operating units and have established calibration procedures. The circuit failure and downscale failure have been deleted from table notation 1 and 2, of NUREG-0472, Revision 3, because it would cost approximately $315,000 to backfit monitors on the Liquid Radwaste Effluent Line, Service Water System Effluent Line and Circulating Water System Effluent Line. If Vepco were to l backfit monitors on these effluent lines, it would take approximately one year from the start of engineering. Vepco believes it is not benificial to backfit on these effluent lines.

In Table 3.3-13, the Waste Gas Holdup System Explosive Gas Monitoring System currently has only one hydrogen monitor and one oxyger. monitor. To install another hydrogen and oxygen monitor, as required by NUREG-0472, Revision 3, there would be a one year lead time from the start of engineering work to final installation and the backfit would also cost approximately $75,000.

Vepco believes it is not benificial to do this backfit. The iodine sampler, particulate sampler and sampler flow rate monitor have been deleted (from HUREG-0472, Revision 3) from the Condenser Air Ejector System because moisture will wipe-out the charcoal system, It will not operate on a continuous basis but grab samples are obtained on a daily basis.

All samplers and monitors listed in Table 3.3-13 are shared between Units 1 and 2. The Containment Purge System has been deleted, from NUREG-0472, Revi-sion 3 because it uses the Ventilation Vent System. The Containment Purge System is not a separate release point. The Auxiliary Building Ventilation System, Fuel Storage Area Ventilation System, Radwaste Area Ventilation System and Steam Generator Blowdown Vent System (of NUREG-0472, Revision 3) have been deleted because they are part of the Ventilation Vent System. The action statements have been revised to reflect the monitoring and sampling frequen-cies.

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Table 4.3-13 has been made consistent with Table 3.3-13. Table notations 1 and 2 (of NUREG-0472, Revision 3) have been changed for the reasons discussed in Table 4.3-12. Table notation 3 (of NUREG-0472, Revision 3) h.s been deleted because Units 1 and 2 are operating and have calibration procedures.

A footnote has been added to the sampler flow rate monitor on the Process Vent System to ensure channel check consists of verifying indica: ions of flow during periods of releases and that a channel check shall be made at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on continuous, periodic or batch releases.

In Table 4.11-1, a footnote has been added under batch releases to account for certain mixtures of gamma emitters that may not be measurable in concentrations near their sensitivity limits. Under these conditions, calculate the concentrations using measured ratios for radionuclides which are routinely identified and measured. The monthly grab sample of gamma emitters under continuous releases has been deleted. The Clarifier System is open to the atmosphere and the effluent is monitored continuously by a radiation monitor and composite sampler.

Throughout RETS, all reference to any organ has been changed to the critical organ. Where this change is applied, a footnote has been added to state that the critical organ is addressed in the ODCM. The reference to the critical organ has been performed to provide clarity.

In Specification 3.11.1.2, of NUREG-0472, Revision 3, the reference to drinking water has been deleted because the nearest drinking water supply is in Doswell, Virginia which is located approximately 20 miles from North Anna Power Station.

In Specification 3.11.1.3 o NUREG-0472, Revision 3, the liquid redwaste treatment system has been changed to the liquid radwaste ion exchanger system because the liquid radwaste treatment system was a very broad area and certain components could be interpreted to be in that system and they should not.

In surveillance requirement 4.11.1.4, surveillance will be performed on a monthly basis instead of a weekly basis because surveillance on a monthly basis is being performed now at North Anna and that seems to be of adequate representation.

In Table 4.11.2, the Process Vent System and Vent. Vent A and B were listed as release points where gaseous effluents are discharged from the facility (Section C). In this sampling analysis frequency, footnotes c and d (from NUREG-0472. Revision 3) were deleted. This is because the amounts of tritium that might be detected are very small since North Anna Units 1 and 2 have been operating for several years. A separate category has been created for the

' Condenser Air Ejector Vent and Steam Generator Blowdown Vent. These release points will not have to be sampled if there is no primary to secondary leakage. A footnote has been added to account for certain mixtures of gamma emitters that may not be measurable in concentrations near their sensitivity limits. Under these conditions calculate the concentrations using measured ratios for radionuclides which are routinely identified and measured.

In Specification 3.11.3, the LCO has been changed to clarify how solidifica-tion pertains to the process control program.

Tables 3.12-1 and 3.12-2 have been renumbered Tables 4.12-1 and 4.12-2. These tables seem to be surveillance requirements rather than limiting conditions for operation. Table 4.12-1, from revision 3, has been renumbered 4.12-3.

North Anna Power Station has 36 routine monitoring locations that sample direct radiation.

For North Anna Power Station, the highest D/Q is SE, NNE, ESE (Site Boundary) for airborne radiation. Sectors SE, ESE, & -NNE are unavailable for airborne sample locations due to power source - restrictions, and/or site boundary located over water. Sector SSE, which is adjacent to SE sector, has an airborne sampling station. Sectors ESE and NNE have an airborne sampling station located within 6-km of the station, which is very accessible to sample. Currently, North Anna has 3 site boundary sample locations at sectors SSE, WSW, and WNW.

For North Anna Power Station, the exposure pathway or sample for waterborne radiation is obtained through monthly grab surface water samples from the circulating water discharge. These samples are currently obtained for monthly gamma isotopic analysis. Composites of each sample are analyzed quarterly for tritium. Historically, no increase in activity has been detected from surface water samples with exception of tritium, which is expected.

Drinking water is not presently sampled. The preoperational environmental sampling program included drinking water. At the conclusion of preoperational environmental sampling program, it was determined that drinking water samples could be terminated.

The exposure pathway or sample of milk for North Anna Power Station with the I highest D/Q is in the SSW, N, and E. There are no dairies located within 5-km in sectors SSW, N, and E. In sectors SSW and S, within 8-km of the station,.

dairy milk samples are obtained. One control milk sample is obtained - in sector NW approximately 11-km from the site, which is a least prevalent wind direction. All milk samples are obtained on a monthly basis. Historically, based on sample analysis, monthly sampling has been deemed appropriate.

Presently, bass, catfish and sunfish are sampled on an annual basis at both upstream and downstream locations. These are the recreationally most important species in the vicinity of plant discharge area.

The exposure pathway or sample of food products has been deleted from NUREG-0472, Revision 3. No irrigation is utilized in the area of the lake.

Presently, sampling of an edible broad leaf vegetation (cabbage), which is located in sectors S and ENE is being performed at harvest time.

Table notation f, of NUREG-0472, Revision 3, has been deleted because the surface waterborne samples will be taken at the circulating water discharge.

Table notation h, of NUREG-0472, Revision 3, has been deleted because the ground water samples are taken for drinking and irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination. North Anna Power Station currently has no irrigation in the

} ' area. Drinking water samples were terminated due to the Preoperational l Environmental Sampling Program. Table notation d in Table 4.12-3, of NUREG-0472 Revision 3, has been deleted and the LLD for I-131 in water has been added.

4 In Specification 3/4 12.2, a dose commitment of 25 percent or greater is used instead of 20 percent or greater so that North Anna can have additional margin. It is also understood that the 20 percent is an arbiturary number.

North Anna Power Station dues not have elevated releases, therefore, all reference to elevated releases has been deleted from NUREG-0472, Revision 3.

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The Specification for reporting major changes to radioactive lir.uid gaseous and solid waste treatment systems has been deleted from NUREG-0472, Revision

3. This Specification currently appears in North Anna Unit 1 License Condition 2.D(3)(e) and North Anna Unit 2 License Condition 2.G.

All reference to radiological effluents, radiological environmental monitoring and radiological reporting requirements have been deleted'from the Appendix B Technical Specifications. The reason is due to the fact that this information is now being incorporated into the Appendix A Technical Specifications.

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