ML20090L505

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Responds to Item Noted in Re Violation of AEC Requirements
ML20090L505
Person / Time
Site: Monticello 
Issue date: 05/10/1974
From: Wachter L
NORTHERN STATES POWER CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20090L503 List:
References
NUDOCS 9102080499
Download: ML20090L505 (2)


Text

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,a NOMTHERN 5TATES POWKR C0MPANY l

MINNE APOLIS. MIN NE SOTA 5 5406 May 10, 1974 4

Mr J G Keppler, Regional Director l

Directorate of Regulatory Operations Region III United States Atornic Energy Comnission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr Keppler:

NONTICELLO NUCLEAR GENERATING P! ANT Docket No. 50-263 License No. DPR-22 Response to Item Listed on Enclosure of Letter Dated April 19, 1974 This letter is written in response to an item noted on your letter of April 19, 1974. Your letter, addressed to Mr Leo J Wachter, Vice President Power Production & System Operation, referred to an activity which appeard to be in violation of AEC requirernents and for which a reply was required. The activity was: "When thu measured release rate of gross beta-gamma activity was 257, or greater of the average release rate of Specification 3.8 A.1, during portions of the period November 1973 through January 1974, only the stack filter cartridges were counted daily. The vent filter cartridges were'still counted i

weekly."

In November 1973, when the noble gas release rate, at the plant main stack, exceeded 257. of the Technical Specification average annual release rate Ifmit, daily counting of the stack filter cartridges was initiated. Daily counting of the stack filter cartridges was continued until the plant was shutdown for the Spring Refueling Outage. However, during the tirne that the noble gas release rate from the plant stack was exceeding 257. of the annual average lisait, the aver-age noble gas release rate from the reactor building vent remained at less than 0.67. of the limit.

Our interpretation of the Technical Specification was that it was intended to require increased surveillance of iodine releases at the point where the noble gas release was above 257 of the limit. Therefore, count-iug of the reactor building vent filter cartridges continued on a weekly basis.

The iodine releases remained below the Technical Specification release t' ate limit.

at all times.

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NORTHERN CTATED POWER CnMPANY Nr'JGKeppler H:y 10, 1974 The major portion of the iodine released f rom the reactor building ventilation stack was due to the processing of the radioactive vaste and to the venting of radwaste tanks to the ventilatinC air.

It was not directly related to the plant noble gas release rate. Also, the effort required to support the increased surveillance on 21 charcoal cartridges and 21 particulate filters would have amounted to approximately 30 additional hours of counting titt.e cach week without contributing significantly to the fodine release data.

In fact it is felt that l

the chorter daily sampling titne would have added unnecessary inaccuracies to the fodine release information.

I Change No.12 to the Technical Specifications, which will become effective af ter the Modified Of f-cac System becomes fully cperational, eliminates the require-n.ent for daily filter surveillance based on noble gas relcase rater.

Instead, it requires daily filter surveillance based on iodine release rates.

It is our feeling that these surveillance requirements should be considered separately for the stack and vent.

Therefore, it is our intention to cubmit a proposed change to the Technical Specifications to clarify the interpretation. Until such a change is ef fective, we will interpret the specification to apply to all filters.

Should you have any questions concerning our actions, please comnnmicate directly with plant management.

Yours very truly, h

L J Wachter, Vice President Power Production 6 System Operation IJW/ma cc J F O' Leary G Charnoff

, Minnesota Pollution Control Agenc'y Attn: E A Prycina i

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