ML20080M090
| ML20080M090 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/26/1983 |
| From: | Gerusky T PENNSYLVANIA, COMMONWEALTH OF |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| ISSUANCES-OLA, NUDOCS 8310030453 | |
| Download: ML20080M090 (2) | |
Text
-
l OT 4
i
+
gctgg;.
-g sQ '.* I
/3
~l COMMONWEALTil OF PENNSYLVANIA JET Xa v
JS /
DEPARTMENT OF ENVIRONMENTAL. RESOURCES t-3 v
J Post Office Box 2063
. es '
~~I
- Harrisburg, Pennsylvania 17120
'83 FP 29 P4 ~
r-September 26, 1983
- s Chi $ci@l S?.ANCH Secretary of the Commission SEN N. U 07" O
U. S. Nuclear Regulatory Commission Washington, DC 20555
-. : - r. :..,j.,,',
,C_ J Attention: Docketing and Servicing Branch (EEW bUWNC '
Dear Sir:
The Commonwealth of Pennsylvania appreciates the opportunity to review the NRC Staff's Safety Evaluation on Steam Generator Tube Repair and Return to Operation for TM1-1 and has the following comments.
The Safety Evaluation does not discuss the impact on the public from routine releases which are within the technical specification limits but which may now be more likely due to operation with repaired steam generator tubes. Although.
it appears from the licensee's safety evaluation that these releases will not be significant, the NRC Staff should perform an independent assessment to provide further assurance that potential additional steam generator leakage will be accept-able. The evaluation should also include the capabilities of monitoring each possible release point to insure that all potential radioactive releases can be
. monitored.
~ A great deal of reliance appea's to be placed upon the condenser off r
gas monitor (RMA-5) to provide continuous information on the primary to secondary leak rate. Since this monitor does not appear to be classified as safety related, an evaluation should be provided to show that backup methods of leakage detection are both timely and sensitive enough to assure that significant releases will not occur if the condenser off gas monitor is not in service.
We disagree with your analysis of the license's steam generator tube leakage / rupture guidelines that a dose rate of 50 mrem /hr. or 500 mrem whole body accumulated dose is an appropriate limit for the isolation of a steam generator having ruptured or leaking tubes. This criteria seems to disregard the ALARA principal of minimizing public exposure for what appears to be primarily operational considerations. Based on our experience during the TMI-2 iccident, offsite agencies responsible for public health and safety will demand that releases be terminated, if at all possible, long before the 500 mrem limit is reached. Unless there is some overriding safety concern, we believe that the primary objective of steam generator tube leakage / rupture procedures should be to terminate releases from the affected steam generator as soon as possible to minimize radiation exposure to the public.
We are aware that several requests for a hearing have been submitted on the license amendment to allow the return of the steam generators to service following repair and that a hearing may have to be held, regardless of the NRC Staff's determination on significant safety hazard. If a hearing is required, we 8310030453 830926 3
PDR ADOCK 05000299 0
Docketing and Servicing Branch September 26,1983 would urge, in the interest of assuring public health and safety, that those proceedings be conducted as soon as possible. In view of the delay which is occuring due to the reopened TMl-1 restart hearings, it appears as if this pro-ceeding could reasonably be conducted prior to a final decision on restart.
Sincerely,
/
THOMAS M.fGERUSKY, Direc or Bureau of Radiation Protection 6
e O