ML20077Q237
| ML20077Q237 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/12/1983 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20077Q242 | List: |
| References | |
| LQA8300216, TAC-08140, TAC-8140, NUDOCS 8309160043 | |
| Download: ML20077Q237 (8) | |
Text
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GENERAL OFFICE Nebraska Public Power District
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Et September 12, 1983 LQA8300216 Director of Nuclear Reactor Regulation Operating Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Mr. Domenic B. Vassallo, Chief
Reference:
1)
Letter from D. B. Vassallo to J. M. Pilant dated May 18,
- 1983,
" RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) COOPER NUCLEAR STATION (CNS)"
Attachment:
1)
Radiological Effluent Technical Specifications (RETS) 2)
Offsite Dose Assessment Manual (ODAM) 3)
Response to Unresolved RETS Issues
Dear Mr. Vassallo:
Subject:
Radiological Effluent Technical Specifications Cooper Nuclear Station NRC Docket No. 50-208, DPR-46 Reference 1 requested the District to submit for NRC review a revision of our proposed Radiological Effluent Technical Specifications (RETS) and to include with that submittal a revised Offsite Dose Assessment Manual (ODAM).
Enclosed as Attachments 1 and 2 please find the requested material.
Additionally, Attachment 3 is the District's voluntary response to the Unresolved RETS Issues, which were transmitted directly to the District by the District's NRC Project Manager.
It must be recognized that upon final acceptance of these proposed documents by the NRC Technical Staff, a period of time will be required to submit final Techneial Specifications and implement the programs at CNS.
The District's satus regarding implementing a Plant Management Information System (PMIS) which will perform these functions was provided April 15, 1983.
The applicable District safety review boards have not reviewed this latest iteration of the RETS.
Upon acceptance of the enclosed by the Staff, appropriate copies will be provided.
OS 8309160043 830912 D
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Page 2 September 12, 1983 Implementation of this program at the beginning of a calendar year is preferable.
Should you have any questions or require additional information, please contact me.
Sincerely, f-
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Jay i t. Pilant Technical Staff Manager 3
Nuclear Power Group JMP/gme:cmzl2/5 Attachments l
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Response to Unresolved RETS Issues Unresolved Item 1 Item 1 Specifications 3.21.B.1.a and 3.21.C.1.a state that concentrations of radioactive material released from the site in liquid and gaseous effluents shall not exceed the concentration specified in 10 CFR Part 20.106.
The Specifications must be reworded to state the concentrations shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II.
Response
Whereas NPPD has proposed Specifications on the concentration of radioactive material in effluents to unrestricted areas based on 10 CFR Part 20.106, the NRC Staff seeks Specifications based on.a narrower basis, namely 10 CFP Part 20, Appendix B Table'II.
The difference is that Part 20.106(a), which implements Part 20, Appendix B, Table II, also allows an averaging time.
A Specification stating that concentration shall be limited to the concentration specified in 10 CFR Part.20, Appendix B, Table II at all times, as requested by the NRC Staff, could be interpreted to mean "at every instant." Obviously, that is not intended by the regulation.
NPPD's intent in invoking the regulation, Part 20.106, is to accommodate the recognized need for a reasonable resolving time for measurements on which compliance is demonstrated. To resolve the difference in view, NPPD proposes to define the intent to 9pecification 3.21.B.1.a by including a clarifying statement in the bases of the Specification.
Specification 3.21.C.1.a has been revised to regulate airborne concentration on the basis of dose rate as suggested by the model Specification. NPPD believes these changes will provide for the degree of control over effluent concentration sought by the Staff.
Unresolved Item 2 Item 2 The annual dose limits for liquid and gaseous releases were not addressed in Specifications 3.21.B.2.a and 3.21.C.2.a.
Response
Unresolved Item 2, concerning the appropriateness of 10 CFR Part 50, Appendix I design objectives as Technical Specifications, seems to be rooted in a question of the intent of the Commission, of Part 50, Appendix I, of 10 CFR Part 50.34a, and of 10 CFR Part 50.36a as they bear on this issue.
In order to attempt to resolve this item, NPPD may request an interpretation by the NRC Ceneral Counsel following the conference telephone call with NRC technical reviewers and our NRC Proj ect Manager referenced in the D. B. Vassallo letter of May 18, 1983.
In the interim, NPPD is resubmitting the Specifications 3.21.B.2.a.
3.21.C.2.a.
and 3.21.C.3.a with quarterly limits but without annual limits.
Unresolved Item 3 Item 3 Specification 3.21.B.2.c states the liquid radwaste treatment system shall be used when the radioactivity concentration exceeds 0.01 pCi/ml.
The concentration was determined in a cost-benefit analysis which is summarized in the bases statement.
If liquid radwastes were released at this concentration, would not the 10 CFR Part 20, Appendix B, Table II concentrations be exceeded?
3
Response
To answer the question in Unresolved Item 3, summary data of liquid radwaste batch releases during a quarter (second quarter, 1981) were examined.
The unrestricted 4rea MPC of the radionuclide mixture in those batch releases was about 1 x 10 pCi/ml and the dilution factor averaged about 4,000.
Assuming these data are typical, release of raduaste liquid containing 0.01 pCi/ml would not be expected to cause aqueous concentrations in the unrestricted area to exceed the 10 CFR Part 20, Appendix B, Table II concentration limit.
Notwithstanding this conclusion, other controls proposed in the Technical Specifications and independent of the Specification on liquid radwaste treatment provide assurance that the unrestricted area concentration limit will not be exceeded.
Specifically, Specifications 3.21. A.1, 4.21. A.1, and 4.21.B.1 provide that batches of liquid radwaste be campled and analyzed before release and that the radioactivity monitor on the radwaste effluent line be set to trip to stop the release in the event the setpoint and, therefore, the concentration in the unrestricted area, would be expected to be exceeded.
Unresolved Item 4 Item 4 The second submittal deleted the Specification requiring curie limits on temporary outside storage tanks.
The Licensee's interpretation of an AIF letter is that a specification is not required.
Response
The only storage tank installed outside to receive radioactive liquid at Cooper Station is the condensate storage tank. NPPD intends to construct a dike around it that will be able to hold the contents of the tank. Thus, a Specification limiting radioactive material content is not warranted for the condensate storage tank.
A Specification on temporary storage tanks for radioactive liquid outside has been inserted as proposed Specifications 3.21.B.3 and 4.21.B.3 to apply to the contingent use of such.
Presently, temporary outside tanks are not being used to store radioactive liquid.
1 Unresolved Item 5 Item 5 Iodine-133 must be included in the gaseous release dose-rate and dose Specification 3.21.C.1.a and 3.21.C.3.a, respectively, and the gas sampling Table 4.21.C.1.
The dose-rate calculation needs to address only the inhalation pathway for a child.
Response
Although it was agreed in conference that I-133 could be omitted, appropriate revisions have been made to the Specifications to include I-133.
The same effluent sampling and analysis is expected to be used for I-133 as for I-131.
Unresolved Item 6 Item 6 The gas sampling Table 4.21.C.1 does not include the requirement for sampling and analysis prior to a drywell purge.
All drywell purges are released through the standby gas treatment system prior to discharge via the main stack. However, this would not quantify H-3 releases nor would it ensure that other releases did not exceed the Part 20 and Part 50 limits.
Response
Item 6 comments on the absence of sampling containment air before each purge.
NPPD's understanding is that this item was not left unresolved at the April 5-6, 1982, meeting.
NPPD explained there that the drywell atmosphere has been clean, that the drywell atmosphere is purged through the Standby Gas Treatment System, and that a purge gas grab sample would not represent the actual release.
Rather, sampling in the ERP (main stack) through which Standby Gas Treatment System effluent is exhausted and analysis in accordance with proposed Table 4.21.C.1 would be more representative. Thus, a purge gas grab sample should not be required.
Unresolved Item 7 l
Item 7 1
The gross alpha analysis frequency in the gas sampling Table 4.21.C.1 was changed from the required monthly to quarterly in the second submittal. This was found to be acceptable provided Note 7 states the quarterly composite particulate sample would be comprised of a portion of the highest activity particulate sample for each month plus one random sample.
1
Response
Note 7 states NPPD's understanding of the means of compcsiting airborne particulate sample media agreed upon in conference with NRC and EG&G staff members.
Utilizing a portion of each weekly sample should yield a more representative composite sample than the alternative suggested in Item 7, regardless of the compositing interval.
For this reason, NPPD prefers and proposes to retain Table 4.21.C.1, Note 7 as proposed in the June 7,
- 1982, draft Specifications.
Unresolved Item 8 Item 8 NUREC-0473 requires the augmented gaseous radwaste treatment system to be in operation whenever the main condenser air ejector is in operation.
The Licensee proposes to use the treatment system when projected air doses via the Elevated Release Point would exceed 0.2 mrad and 0.4 mrad for gamma and beta radiation, respectively, as stated in Specification 3.21.C.4.b.
Response
Specificctions 3.21.C.4 and 4.21.C.4 have been revised to require offgas treatment whenever the main condenser air ejector is operating normally.
Unresolved Item 9 Item 9 Specification 3.21.C.6.a states that the gross radioactivity rate of noble gases at the main condenser air ejector shall be limited to <1 Ci per second.
The Licensee stated they would demonstrate in the bases statement that 1 Ci per second at the air ejector is as conservative as 100 pCi per second per MWt after a 30-minute delay.
Response
This demonstration has not been performed at this time.
Unresolved Item 10 Item 10 If the Radiological Environmental Monitoring Manual (REMM) is to serve the purposes of part of the ODCM, the REMM requires the same controls as the ODCM, e.g., prior approval, methods of revision, report changes, etc.
Footnote a of Table 3.21.F.1 states the sample station locations for the environmental monitoring program are shown in the REMM.
This manual is maintained by the Environmental Affairs Division of the Power Operations Group.
The REMM is defined as the manual that describes the radiological environmental monitoring program for CNS.
The NRC or its contractor (EC&G) must review the REMM.
Alternatively, the three items listed under No. 23 of the attached ODCM issues should be added to the ODCM.
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Response
Specifications 3.21.F and 4.21.F state provisions and controls for changing radiological environmental sampling locations and for reporting changes to the NRC.
The other relevant information is the locations of the sampling. NPPD will maintain a map and a list of the current locations.
Any changes made after the specifications are implemented will be reported to the NRC in accordance with Specifications 3.21.F.4 and 3.21.F.6.
Unresolved Item 11 Item 11 The land use census specification in NUREG-0473 requires additional information to be obtained if there are elevated releases. The Licensee will be requested to restate their position why this additional data requirement is not included in Specification 4.21.F.2.
Elevated releases are addressed in Section 3.0 of the ODCM.
Response
Specification 4.21.F.2 concerning land use survey was discussed thoroughly in conference including NRC, EG&G, and NPPD Staff members.
It is NPPD's understanding that the Specification proposed was acceptable to the NRC Staff.
Cooper S tation ' is located in a rural area and the prevailing use of surrounding land is for agriculture.
NPPD believes an annual survey of land use within three niles as proposed in Specification 4.21.F.2 will be adequate to identify the pathways contributing the most exposure potential to a member of the public during seasonally or annually averaged environmental conditions.
Cooper Station has an elevated release point, the ERP, which, according to guidance in the model Specificatiors, would apparently warrant a more extensive land use survey than proposed.
Yet, topnowthelocationsofall milch animals and all gardens greater than 50 m in areas producing broad-leafed vegetation would seem unlikely to substantially affect conclusions derived on the basis of the proposed land use survey.
Unresolved Item 12 Item 12 Demonstrating compliance to 40 CFR Part 190 is not stated in the requirements for the Semiannual Report.
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Response
If Technical Specifications implementing 10 CFR Part 50, Appendix I are met on a six-month basis it would seem unlikely that a station which has an annual history of compliance would fail to meet the 40 CFR Part 190 standard halfway through the year.
Some support for this view may be derived from a report on 8
methods of demonstrating compliance with 40 CFR Part 190.
- Moreover, Specification 3.21.D.1 is appropriately conditioned to require an assessment of compliance with 40 CFR Part 190 dose limits if calculations performed more frequently than once per year should indicate it may be warranted.
Since Federal regulations do not require compliance with 40 CFR Part 190 to be demonstrated on a semiannual basis, NPPD has proposed to report calculated doses to a member of the public in the Radiological Environmental Annual Report.
Unresolved Item 13 Item 13 A definition should be included for " Unrestricted Area."
This term is used in the liquid dose Specification 3.21.B.2.a.
Response
I The term " Unrestricted Area" has been replaced by the term "Of f site."
A
. definition of "Offsite" has been added to Section 1 of the Specifications to clarify it.
" Member of the Public" has also been defined in Section A.
Unresolved Item 14 Item 14 The following are included in the Licensee's proposal and may be deleted as they are superfluous or no longer NUREG-0473 requirements. Other statements in these categories were identified in the aforementioned telephone l
conversations and will not be repeated.
l A.
The surveillance checks in Table 4.21.A.1 for the Condensate Storage Tank Level Indicators may be deleted.
B.
The prompt notification requirement contained in Specifications 3.21.B.1.b and 3.21.C.I.b may be deleted.
l See wording of Revision 3.
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Response
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The items mentioned have been deleted from the Specifications.
8 F. Congel, 1980, Methods for Demonstrating LWR Compliance weih the EPA Uranium Fuel Cycle Standard (40 CFR Part 190), USNRC Report NUREG-0543, I
l page 11.
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