ML20126M417

Forwards Response to 770628 Request for Review of Draft App I Tech Specs.Suggests All Reporting Requirements Associated W/Each Limiting Condition for Operation Be Included Under Action

ML20126M417
Person / Time
Issue date:	07/18/1977
From:	Roberts I NRC OFFICE OF STANDARDS DEVELOPMENT
To:	Eisenhut D, Vollmer R Office of Nuclear Reactor Regulation
References
ZECH, NUDOCS 8106180039
Download: ML20126M417 (13)

Text

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JUL 1 8 G77 MEMORANDUM FOR: R. Vollmer, Assistant Director for Site Analysis, DSE D. Eisenhut, Assistant Director for Operational Technology, DOR FROM: I. C. P.cberts, Assistant Director for Site and Health Standards, 50

SUBJECT:

REVIEW OF DRAFT APPENDIX I TECHNICAL SPECIFICATIONS In response to your request dated June 28,19// , memoers of my staff have reviewed the Draft Appendix I Technical Specifications and their cormients on the format and content of these specifications are enclosed.

You also invited comments as to whether the radiological environtnental monitoring technical specifications should be issued as a non-safety specification such as Apcendix 3 or C (DSE recommendation) or as standard Appendix A Safety Specifications (DOR recort=endation). Having considered the arguments for both positions, we favor the DSE recomendation. The primary reasons for this are that we do not consider the requirement for j radiological environmental monitoring to be a " safety" specification as g the term " safety" is used in the context of 10 CFR part 50, and because  :

the requirement for this tyce of monitoring is not directly related in the specifica:icns to liW.s on the operation of the station; in other words, radiological environmental monitoring is " surveillance" which is not associated with any true " limiting" conditions for operation.

I wish to call your at'ention to itam 7c in Fred Anderson's coments. It is icoortet that this issue be addressed and resolved. ,

j A. C # Rooerts h ' Ass W1stant Director for Site and Health Standards '

Enclosurs: as stated ec: R. DeYoung W. Gannill K. Goller ,

H. Thornburg V. Moore W. Burke L. Barrett F. Congel THIS DOCUMENT CONTAINS POOR QUAUTY PAGES

{L. Anderson Cohen

""6150039 - -

, Ce/r.ents on Draft Appendix I Technical Specifications General coment on location of recortine recuirements: Some recorting requiremencs ("Special Reports") are inciucec unoer " Action" wnin is logical because to recort is to take one type of action. However, the regular annual and semiannual reports are included under " Surveillance" and this is not logical because surveillance means "the act of observe or the condition of heang observed". Suggest the all reporting requirements associated with e.ach LCO be included urder " Action".

o. 3/4 3 49 " Action 19": Change " sensitivity" to " limit of' detection"i

("sensi:ivity" is the slope of the calibratien curve and should not be used to..~

denote detection limit) -

o. 3/4 11-2: Bases should be provided for the entries in this table, and particularly in the selection of the particular radionuclides listed.

Last Column: Change heading from " Detection Capabilities" to " Lower Limit of Detection"

p. 3/4 11-3, Para. a: Instead of referring to HASL 300, define the LLD explicitly as it is defined on p. 3/412-3 modified to yield conca.mtration units of ft C1/mi rather than pCi per unit mass or , volume.

o. 3/4 11-3, para. b. 1st sentence: Change " sensitivity limit" to " detection 11m1 " (see corm: enc for p. 3/4 3-49 abbve . _

o. 3/411-8. Table 4.11-2: Fe-55 should be included in this table if its cetermination is required by Table 4.11-1.

p. 3/411-14, Table 4.11-5:

4.11-3. Fe-55 snould be included if it is included in Table

?-32 snouic ce omitted if it is not included in Table 4.11-3.

p. 3/4 11-17. Table 4.11-3: Note that table nu:.bers 4.ll-x are not in the order of :nelr aopearance in :ne text; the order is 4.11-1,2,4,5,3.

Bases should be provided for the table entries, particularly the particular radionuclides included.

See comment above on Table 4.11-5 concerning the inconsistency betaeen Tables 4.11-3 and 5 for the radionuclides listed.

Change the heading of the last column frem " Detection Capabilities" to " ower Limit of Da.tection"

p. 3/411-18: In paragraph "b", change " sensitivity limit" to " detection limit" Section 3/4.12. General Com:lents on the Fomat of the Specifications on Raciciogical Environmental Monitoring

1. Tne femat used is illogical, ' inconsistent with othe? specifications 'in this format, and will lead to confusion and conflict for the following reasons:

1) The "LCC" is actually only a recuirement that a monitoring crogram be conducted.

This monitoring requirement is unrelated in these soecifications.to the concrol of the station coerations (unlike the "LCOs" in the effluent technical

_ specifications and existing Acc. A Standard Technical Specifications)

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2) The "LC0" and the " Surveillance Requirement" are actually both specifications of one and the same environmental monitoring requirement; the " Surveillance Re.quirement" given is simply a more detailed statement of the monitoring requirement than that given as the "LC0"

3) The treat:nent of a monitoring requirement as an LCO is inconsistent with the definition of LCO in 10 CR Part 50: " Limiting Conditions for Operation are the lowest functional capability or perfor-nance levels of equipment required for safe operation of the facility" (emphasis added). Neither is it consistent with the definition that has been croposed for addition to 10 CR Part 51: " Limiting conditions for Operations are controls i:::cosed on plant discharges, operations and other parameters which, if not exceeded, should result in acceptable environmental impacts" (emphasis added).

4) The LCO format for radiological monitoring recuirements (whether in"A::cendix A" or " Appendix 3") is inconsistent with the format for non-radiological monitoring requirements. The same for=at should be used for all monitoring requirements that are not related in the tech. specs. to the control of the

,acility, whether these monitoring requirements are radiological er non-radiological.

We suggest that the format for monitoring recuirements snould include the follow-ing major elements: 1) Specification of the monitoring recuirement(s), 2) Action

and-3) Bases. In this format, " Applicability" would be included within the specification of the monitoring recuirement (although it seems necessary to specify applicability only when it is not "all modes") and "recorts" would be included under " action". However, " applicability" and " reports" could be separate subsections if there is sufficient justification.

o. 3/4 12-1. Action c.: This specification should allow for the fact that it may De 1moossicie to finc locations for replacemen; samoles Suggest adding "...or states :na such locations cannot be found" to the end of the first sentence and add "...or the fact that ruca locations are unavailable has been reportad" to the end of the second sentence. .

o. 3/412-(3-5)' Table 3.12 Numoer of Samoles and Sa cle Locations For " Direct Raciation," tne original intent was to nave a 2 measurements of dose at each location. Using thernoluminescence dosimetry (TLD),' t. tis can be acc:r::plished by having 2 2 thermoluminescence choschors, or readout areas , in one dosimeter (See ANSI N545-1975, of thercoluminescence onoschors andendorsed dosime:ersby)R.G.

. 4.13 for the definitionsThus, fcr " Direct Radiat suggest changing " 2 2 cos1 meters... * :o 'a i dosimeter containing 2 2 ther -

Ocluminescence phosphors or readout areas..." (Note: Diis cort:::ent a::clies also to the RAS Branch Technical position).

ne. 3/a 12-(3-5) . Table 3.12-1 : Samoline and Collection Frecuencv:

.xpression of ne frecuency as "once ser i cays", "once per 3i cays", etc.,

instead of " weekly", "montnly" etc., increases the ambicuity of this specification 5e.cause it is not at all clear which 7 days, or wnich 31 days etc. In other words, wnen do you start counting :ne specified :1 e period? The intent of those l _ _ _ _ _ _ _

who originally wrote this specification was "at least once per calendar week", etc.

It is desirable to write the specification so as not to allow sampling near the end of one calendar period and the beginning of the next; however, the "Aopendix A" language does not eliminate this possibility. We suggest that the frequency be changed to "once per calendar week", once per calendar quarter," etc.

The footnote concerning composite samoles (p. 3/412-4) is incorrect and is needlessi restrictive. (see footnote "i" to Tacle 2 of the RAB Branch Technical Postition).

Suggest changing this footnote to " Composite samples shall be collected by continuous sampling or by collecting aliquots at intervals of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less".

For " Direct Radiation" the intent is to allow either monthly or cuarterly dosimeter exposures. The specification as drafted recuires ben monthly and quarterly. Suggest adding the word "or" between the "31 daTv and "92 day" specs.

po. 3/4 12-(3-5). Table 3.12-1: Tyse and Frecuency of Analysis Some of :ne en:rles in .nis column appear to confuse tne ":ype and frequency of analysis" with " sampling and collection frequency" so that it is unclear as to which sar:cles are to be analy:ed for what.

"Ai rborne": Substitute " Determine I-131 in each canister" for "Analy:e at least once per 7 cays for I-131". Substitute "... of samples ecliected during each calendar quarter". for "... sample at least once per 92 days".

Direct Radiation: See cec =ent on "Sa:pling and collection frecuency for this type or monitoring. Suggest adding the word "or" between the "31 day" and "92 day" specification. - - -

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Waterborne

a. Sur' ace: Delete ".. . :ar:cle at leas: ence per 92 days", and add

... of samoies coilected during each calendar quarter". -

' Waterborne 'c.

Drinkine: Substitute " Determine I-131 in ..." for "Radiodine analysis of ..." (for greater clarity). Delete "... sarole at least once per 92 days" and~ add "... of samples collected during each calendar quar:er".

Milk and Food Products: Change "Radiciodine analysis" to "I-131 Analysis" for clar1:y.

o. 3/4 12-7, Table 4.12-1 : The title is incorrect. These are not " minimum" LLO values; :ney are " maximum" LLD values; i.e. , they are uceer limits on the lower limi .s of detection. Change title to " Maximum Values for the Lower Limits ~

of Detection (LLD) aa Notation fcr parent-daughter pairs is ambiguous. It is not clear whether the corresponding table entries refer to the (a) the parent or the daugnter, or (b) the paren: plus the daughter. I believe 1;.should be the carent or the daughter with the notation changed, for example, frem ""Zr-Nb" to "95Zr or 95?ic'.

c. 3/4 12-g, Footnote c: Correct foo:nete by adding "... for atm scheric releases ano 10 alii 1 rems / year for liquid releases. . ." betwe<.n ". .15 mrem / year. . . "

and " . . . us ing the assumptions. . . "

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p. 3/4 12-12, " Cross-Check procram": Tnere are a number of problems with this specifica:1on as craf:ec.

(a) Participation in the EPA " Cross-Check" program, or similar program, is only one part of the total quality assurance program for radiological effluent and environmental monitoring that is described in the Regulatory Guide being developed on this subject. Therefore, we suggest substitutino for this specificatfor a more general specification that the licensee (and his contractor) have a quality assurance program containing the program elements presented in this regulatory guide (which is scheduled to be issued this calendar year).

(b) For the specification on the " cross-check program" only, the following cocznents apply.

The specification emits the imoortant condition (given in the RAB Branch Position) that participation in the " cross-check" program shall include all of the determinations (sample medium - radionuclide combinations) that are offered by EPA and that also are included in Table 3.12-1.

Reference should not be made to the " control limits defined in EPA - 600/4-77-001, January 1977". Tne casts for these limits is, at best obscure, and the values are open to question. We have requested that I?A document the basis for these values, review them with NRC in the light of current capabilities, and revise them as appropriate and :::utually agreeable. Until this has been acccmolished, era's control limits should not be used as the basis for technical specification requiremencs.

c. B 3/412-1, Soecification 3/4.12.1: Add the following to the end of the seconc sentence in :ne seconc paragraph: " .. for atmospheric releases and 10 millirems / year for liquid releases.

A. B 3/412-2 Section 3/4.12.3: This statement is incorrect, because partici-pation in :ne " cross-cnecx" program does not " ensure that measurements.. . are per# armed with precision and accuracy".

Suggest revising to read: " Participation in the EPA cross-check program is required to provide some measure of the precision and accuracy of measurements of radioactive material in environmental samole matrices in order to help assure that the results of such measurements are reasonabiy valid".

c. 6-16a, " Annual Radiological Coerating Recor*": Change title in heading and tex: to "Annuai Raclologicai invironmentai Operating Recor ", for clarity.

Section 6.9.1.6: Change due date of recort from April 1 back to May 1 per prior agreement of cocni: ant staff in response to com.ents on R.G. 4.8. Change " unit" to "s-tation". (Tnere should be one recort covering all units on the station, not separate reports for each unit).

Section 6.9.1.7: Tne dose calculations called for in the last paragraoh should be inciucec w1:n the other dose calculations in the semi-annual radioactive effluent release recort, not in this annual radiological environmental re: ort because the dcse calculations should be done using the effluent data.

c. 6-16a, footnote 5: Tnis footnote should acoly to the " semi-annual radioactive effluent release report" and not to the " annual radiological operating report")

(See cocnent above concerning cnanging " unit" to " station" in section 6.9.1.6).

p. 6-16b, Table 6.9.1: Add the words " Format for..." to the beginning of the ti tl e.

Change footnote (a) to read, " Nominal Lower Limit of Detection (LLD) as defined in footnote (a) to Table 4.12.1".

o. 6-19b , Table 6.'9-2: Need to clarify parent-daughter notation to show clearly wnether tne reporting levels given apply to the parent or tne daughter, or the parent clus the daughter. For examole, "Zr-Nb-95" shcuTc be "Zr-95 or Nb-95",

or "Ir-U Nb-95", or the two nuclides should be listed separately with different reporting levels.

hu8 &

John Buchanan Environmental Standards Branch l

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Carments on Draft Accendix I Technical Soecifications (June 27. 1977) .

This draft of Appendix I technical. specifications represents a vast improvement in the organi:ation and separation of subject matter.

These changes, unfortunately, have raised additional questions re-garding guidance to the user and bases for specific requirements which have been added. Soecific comments as requested by the cover memorandum of June 28, 1977, are as follows:

1. A general question is raised regarding Tables 3.3-11 and 3.3-12.

What will be the basis for the alarm / trip setpoint levels and how will these values be established by the licensee or NRC staff?

Since a relationship is assumed to exist between the activity level set point and the flow rate set point, these set points should be jointly established in the tables with ranges provided.

The need for liquid waste tank level set points as limiting con-ditions for operation is not understood but the total gross activity may be an im:ortant condition which is not indicated by volume in tanks. In most cases of monitoring for radioactivity releases, both a high and a low level alarm set poin: are needed for operator information. There is no indication that the "to be established" set points for the activity monitors, either liquid .

or gas, will be appropriate for a range of flow rates as related /

to needed accuracy for system responses. The relationship of

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samples flow rate to either the monitor set point or the main flow rate for the gaseous effluent is not provided. The need '

s for these flow rate set points is not provided. Do the hydrogen and/or the oxygen m:nitors depend upon a knowledge of the ficw rates or are these monitoring systans independent of the waste gas holdup system?

2. In Specification 3.11.1.1, the specification needs to reference the notes applicable to Table II and that these limits aoply to releases in liquid effluents only. The referenced noble gas limit is appropriate for any mixture of dissolved noble gases.

3. In Specification 3.11.1.2, the levels stated are not limits and can not be so specified in contradiction to the regulations.

These levels can only recuire the stated surveillance actions of Appendix I. The level given in b. does not exist in the regu-lation and should be deleted. We recommend the use of the word- i ing from the proposed technical specification guidance given in Appendix I. l "3.11.1.2 If the cuantity of radioactive material actually released in liquid effluents to unrestricted areas during any calendar quarter is such that tne resulting radiation ex-posure, calculated on the same basis as used in the Final Environmental Statement, would exceed 1.5 mrems to the total l

body or 5 mrecs to any organ, the licensee shall:

a. Make an investigation to identify the cause for such' release rates;

b. Define and initiate a program of corrective action; and

c. Provide a special report pursuant to Specificatien 6.9.2 describing these actions within 30 days from the end of the quarter during which the release occurred.",

The Actions stated are not actions but regulations whereas b. is contracictory to the regulations. The action that should be stated is that the licensee shall take the corrective action described in the Special Report as soon as practical and reduce the radioactive material releases to as low as reasonably achievable. Action c.

should remain.

4. In Specification 4.11.1.2.2, Specifications 6.9.1.8 and 6.9.1.9 should be referenced as to the location of the required report in the semi-annual report. Such cross-referencing should be done throughout the specifications wherever appropriate. _

5. Specification 3.11.1.3 requires operation of the cleanup systecs at 10 percent of annual design objectives on a daily basis. This .

requirement is to be based upon a calculation and not a known release /

dose relationship. We consider this specification to be contradictory -

to both the intent and curpose of ALARA as given in Appendix I.

We recommend that, if a daily dose level is to be used for system operation, the level be increased :: the ALARA design objectives. We consider the daily dose analysis to be more than adequate to assure operation of the system on a reasonable cost / benefit relationship.

The specification should state as indicated in Corment 3 for a rewrite of Specification 3.11.1.2 that the predicted excesure will >

be calculated on the same basis as used in the FES.

The proposed action does not result in any penalty excect another report that will not be read and does not rescend to any wortnwnile need. If the soecification is really an LCO, the releases snould be stopped until the equipment is operable. If the releases at these levels are not that serious, a seven day or fourteen day period of grace should be permitted befrre releases need be stop ed if the equipment is not fixed. We recomr.end that a seven day ceriod be used in the Action section before releases need be restricted.

Reporting of such events should be proviced in the semi-annual report only - not another Special Report. __

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6. For Section 3/4.11.2, the subtitle should not be Oose Rate but Annual Dose.

7. Specification 3.11.2.1 requires many changes to comply with the regulations and to represent current knowledge in radiation protection. .

The gaseous effluent requirements relating to part 20 limits should be '

written in the same format as used in Specificatica 3.11.1.1 for liquid effluents.

"3.11.2.1 The annual dose from radioactive material released in gaseous effluents from the site to unrestricted areas (see Figure 3.11-2) shall be limited by the folicwing expressions:"

Figure 3.11-2 as was used for Figure 3.11-1 on liquid effluents should show the appropriate areas designated as unrestricted for purposes of radioactive effluents within Part 20 cefinitions for areas beyond site boundaries. Usually this area sill be represented by the fenced property line around the site.

The complexity of- the equations fm the gascus effluents is unwarranted by the purpose for their existence, i.e. , to establish isolation of the off-gas system or to stop the release of radioactive material to the environs. The approach used for the equivalent LCO 1(mits on liquid effluents should be used on the gaseous effluents. Other points which are , .,

related to technical matters are discussed below.

a. Use of semi-infinite cloud geometry with highly accurate dose conversion factors is inconsistent. We recommend the use of finite cloud geometry in the equations.

b. Separation cf the gaseous effluencs into isotopic families in some cases and into the form of the radioactive material in others for the limits is difficult to follow. We recommend the use of total radioactive material for de- 4 .

termining dose to whole (total) body and the skin. The use of the noble gases and daughters as the major contributors is appropriate and should be the basis for the actual analysis,

c. The correct depth dose analysis should be performed. The use of 5 cm for depth of total body dose is not defendable. -

NCR0 Report No.14 and !CRp Recort No. 23 have provided additionai information on standard man parameters and depth dose considerations that reflect on these comments. The s

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recomended NCRP skin depth for skin dose calculations is 0.05 mm (5 mg/cm2) as compared to the subject documents value of 7 mg/cm2 The recommended NCRP lenses of the eyes depth is 3 to 4 m (300 to 400 mg/cm2) which is a critical organ as compared to the subject documents value for total body depth of 5 cm (5000 mg/cm2). The ICRP data indicates that mst of the red bone marrow present in man is located in surface located bones such as chest, vertebrae, cranium and hips. The indicated depth for this critical organ would be about 3 m (300 mg/cm2) as coccared to the total body depth of 5 cm used by the NRR staff which was assumed to apply to the bone depth. Obviously this assu=ption cannot be correct. The ICRP and NCRP indicate a testes depth for genetic depth dose of 2 tothan rather 3 mthe (200 to(1000 1 cm 300 mg/cm2)2) mg/cm depth value given in the subject documents. These ICRP and NCRP depth values indicate that a single depth dose analysis at a depth of 3 m (300 mg/cm2) would qualify to assess the genetic dose and the total body dcse representing the critical organs of head, lenses of the eyes, red bone marrow and testes. The use of 5 or 7 mg/cm2 depth for the skin depth dose analysis would appear to be academic. The conversion factors recomended for use in the equations have been derived using the stated depths for dose analysis. We recomend the use of 0.3 cm (300 mg/c.2) -

for total body and 0.005 cm (5 mg/cm2) for skin.

d. The thyroid dose limit should be analyced on the basis of total radiciodine with the appropriate factors to assess the cow-milk-infant pathway unless this pathway is not the most cri tical .

e. From experience, the bone and lung dose limit should be analyced on the basis of total radioactive particulate matter with the accropriate factors to assess the most critical pathway. Tnese factors will not be the same as those used to determine infant thyroid dose through the cow-milk-infant pathway as implied by the proposed equations. Tne critical organ for particulate matter in the gaseous effluents will i not be the same as imol' " by the proposed equations. We recomend that the Par equivalent release limits be separated into thyroid adiciodine) dose levels and bone or lung (radioactive pi ticulates) dose levels.

8. In Table 4.11-4, the columns f air dose factors should be deleted.

As a matter of fact, unless the a dose conversion factors are site related, the entire table shou, not be given in the technical specifications. inis come.n would apply to Table 4.11-5 as well .

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9. In the ACTION Section of Specification 3.11.2.1, the requirement is for prompt notification in accordance with Specification 6.9.1.12. An instantaneous release rate of the magnitude associated with these limits

. does not warrant such action as proposed. A more appropriate reporting I requirement would be Specification 6.9.1.13 as a 30 day report of an uuplanned offsite release so that the consequences would be evaluated and reported. We recommend this change in reporting requirements es an action item. The same commant would be appropriate for Specification 3.11.1.1 on liquid effluents under action itecs.

10. The comments made regarding Specificatien 3.11.1.2 in Comment 3 above

, are appropriate for the requirements stated in Specification 3.11.2.2.

The wording recommended for Specification 3.11.2.2. is the following:

"3.11.2.2 If the total quantity of radioactive material actually released in gaseous effluents to unrestricted areas during any calendar quarter is such that the resulting radiation exposure, calculated on the same basis as used in the Final Environmental Statement,' would exceed 2.5 mrers to the total body or 7.5 mrems to the skin, the licensee shall:

a. Make an investigation tc identify the causes for such release rates; s

b. Define and initiata a program of corrective action; and

c. Provide a special report pursuant to Specification 6.9.2 describing these actions within 30 days frem the end of the quarter during which the release occurred."

The use of the Appendix I air dose levels for gamma and beta radiation in these specifications would be appropriate if the use of Part 20 dose limits for Specification 3.11.2.1 would use air dose analysis. The use of both methods in the technical specification LCO requirements is not consistent or good practice. If the air dose levels are used to meet Appendix I requirements only the whole body dose limit from Part 20 without depth dose analysis should be used for the requirements in Specification 3.11.2.1, i.e. , delete the skin dose release level requi rement.

The Action section should be rewritten consistent with Comment 3.

and ne Appendix I dose levels finally selected as requirements.

Specification 4.11.2.2.1 would not require revision if the above suggested changes to reflect air dose levels are made but would recuire major revision if total body and skin dose levels are to be reflected in the requiremen:5. The attached Figures 3.11-2 and'3 need to be deleted from tne technical specifications as inappropriate additions.

11. Comment 2. (Specification 3.11.1.2) and Cc= tent 10 (Specification 3.11.2.2) are applicable to Specification 3.11.2.3. The wording recommended for Specification 3.11.2.3 is the following:

"3.11.2.3 If the total quantity of all radioactive iodines and radioactive material in particulate form actually released in gaseous effluents to unrestricted areas during any calendar quarter is such that the resulting radiation exoosure, calculated on the same basis as used in the Final Environmental Statement, would exceed 7.5 mrems to any organ, the licensee shall:

a. Make an investigation to identify the causes for such release rates;

b. Define and initiate a program of corrective action; and

c. Provide a special report pursuant to Specification 6.9.2 describing these actions within 30 days from the end of the quarter during which the release occurred."

The Action section should be rewr.itten consistent with Comment 3.

The rewritten recuirements complement the proposed revision to Specification 3.11.2.1 discussed in Comment 7. for the radiciodines and radioactive particulates release limits to meet Part 20 limits.

Specification 4.11.23.1 would not require any modifications to agree with the above proposed changes. The attached Figures 3.11-4,5,6 and 7 need to be deleted as inappropriate in technical specifications.

12. Specifica: ion 3.11.2.4 needs to be revised in the same manner proposed for Specification 3.11.1.3 as discussed in Comment 5. for the same reasons.

13. The following sections of the technical specifications have not been reviewed so that no corcents means non-review, not approval. These sections are: 3/4.11.3 and 3/4.12.

14. In general, the Bases sections are very brief and do not represent adequate justification for the recuirecents represented. Severai spe:ific comments on Bases for 3/4.11.2.1 are that concentrations would be in excess of 10 CFR Part 20 limits on an instantaneous basis for the maximum dose rates specified due to the method used to derive the equivalent levels and the annual dose limits are not necessarily the maximum dose rates as stated in the bases.

15. Table 6.2-1 in the single asterisk note should delete the word "Rea c to r" . Inconsisten with Part 55.

k e m wees=.. . .

16. Specification 6.9.2 e. indicates a need for a special report for excessive radiation doses rather than excessive releases of radio-active mterial neither of which would be true for the Specifications referenced. Appendix I requires 30 day reports for releases which if calculated in accordance with FES methocs could exceed twice ALAP.A . Such levels are not excessive even if they could be measured.

This item should be written to indicate Appendix I release levels exceeded is cause for the special repore.

Ad wW Fred Anderson Site Designation Standards Branch O .

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