ML20127C411
| ML20127C411 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/21/1984 |
| From: | Olshinski J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243 NUDOCS 8501160530 | |
| Download: ML20127C411 (2) | |
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NUCLEAR RE^ULAT;RY COMMISSEN g
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ATLANTA. GEORGIA 30303 o
NOV 21 GM MEM",RANCUM FOR:
Darrell G. Eisenhut, Director Division of Licensing, hRR FROM:
John A. Olshinski, Director Division of Reactor Projects
SUBJECT:
TECHNICAL SPECIFICATION REQUIREMENTS - QUALITY ASSURANCE FOR RADIOLOGICAL EFFLUENT AND ENVIRONMENTAL MONITORING During a recent review of the Technical Specifications (TS) for Catawba Unit 1, my staff identified tne need for a TS requirement for procedures to implement Regulatory Guide 4.15
" Quality Assurance for Radiological Monitoring Program
-(Normal Operations) - Effluent Stream and the Environment." We were informed by the cognizant licensing project manager that reference to Regulatory Guide 4.15 was no longer a part of the Standard Technical Specifications and, therefore, would not be included in the Catawba TS.
We feel that failure to include requirements for quality assurance in conformance with Regulatory Guide 4.15 will substantially weaken the cuality of radiological and environmental monitoring.
Most Region II facilities licensed after 1980 have requirements to utili:e Regulatory Guide 4.15.
This has not imposed an unreasonable burden on licensees and has enhanced the quality of the monitoring programs.
A comprehensive quality assurance program is necessary to ensure the accuracy and validity of licensees' effluent measurements that demonstrate compliance with regulatory limits.
Recently, the implementation of standard Radiological and Environmental Technical Specifications (RETS) has emphasi:ed the need for accurate effluent measurements since those measurements are utilized for assessing radiation doses to the public and for demonstrating compliance with EPA Fuel Cycle Standards (40 CFR 190).
Since the fuel cycle radiation exposure standards for members of the public are quite low, the need for accuracy in effluent measurements is even greater. Radiological measurements a e an integral part of the health physics program including the following areas:
respiratory protection, bioassay, emergency response, calibration of effluent monitors, and post-accident liquid and gas measurements. Failure to make accurate radiological measurements could severely impact these areas and compromise both worker and public safety.
E, -ay of backg-ounc, tne addition of Regulatory Guide 4.15 to :ne stancard RETS
. s eauested oy tne Office of Inspection and Enforcement. Regulatory Guide 4.15 was in:luded in the original versions published as NUREG-0472 and NUREG-0473, and trese versions were reviewed by the various Offices and Regions prior to 115.an:e. Dueing the past few years, there have been many revisions to the RETS
- i:n resultec from tneir irclementation at operating plants.
During the
' :* e entatier ::co:ess, many licensees indicated that they wc"ld not incluce a
- -- *. e ; :: N galat:*y Guide 4.15 in : e'-
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- -'s si gle issue was not of sufficient importance to delay implementation. We were assured that TS for new licenses would continue to reference Regulatory Guice 4.15.
Contrary to these assurances, the standard RETS for both operating and NTOLs have been changed to delete Regulatory Guide 4.15.
This was done witreut comprehensive review within the agency and is a position that, we believe, shculc be reconsidered.
We have learned that some licensees with Regulatory Guide 4.15 requirements are consicering requests to have these requirements deleted from their TS.
If approved, this would have a negative impact on the quality of monitoring programs l
by eliminating the requirements for a comprehensive quali,ty assurance program in the radiological monitoring area.
The e is a need for a specific regulatory requirement such as that provided by referencing Regulatory Guide 4.15 in the TS.
If this cannot be achieved l
througn TS, appropriate rulemaking should be initiated to correct this deficiency.
l (d, tCDlo John A. Ol'shinski I
cc:
T. Martin, RI J. Hind, RIII R. Bangart, RIV I
R. Scarno, RV e
v-sug Io, UNITED STATES Qi NUCLEAR REGULATORY COMMISSION l
W ASHINGTON. D. C. 20SSS
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January 28, 1985 TO ALL BOILING WATER REACTOR LICENSEES AND APPLICANTS Gentlemen:
SUBJECT:
CLADIFICATION OF EQUIVALENT CONTROL CAPACITY FOP STANOPY LIQUID CONTPOL SYSTEMS (Generic Letter 85-03) l Paragraph (c) (a) nf 10 CFR 50.62 states, in part:
Each boiling) water reactor must have a standby liquid control system (SLCS with a minimum flow capacity and baron content equivalent in cnntrol capacity to 86 gallons per minute of 13 weight percent sodium pentaborate solution.
The "ecuivalent in centrol capacity" wording was chosen to allow flexibility in the implementation of the requirement.
For example, the equivalence can l
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be obta.in~ed by increasing flow rate, boron concentration or boron enrichment..
I The 86 gallons per minute and 13 weight percent sodium pentaborate were values I
used in NEDE-24222. " Assessment of BWR Mitigation of ATWS, Volumes I and II,"
December 1979, for BWR/4, BWR/5 and BWP/6 plants with a 251 inch vessel inside l
diameter. Tha* diffarent values would be ecuivalent for smaller plants was recognized in hdDE-24222:
The flow rates given here are normalized from a 251-inch-diameter l
Vessel plant to a 218-inch-diameter vessel plant, i.e., the 66 GPM control Ifouid injection rate in a 218 is equivalent to 86 GPM in a 251.
This is done to bound the analysis...(pp. 3-171 The important parameters to consider in establishing equivalence are vessel l
boron concentration required to achieve shutdown and the time required to l
Pchieve that vessel borar concentration. The minimally acceptable system l
shculd show an ecuivalenca in these parameters to the 251 inch diameter vessels studied in t!E0E-24222.
There are ne raporting requirements associated with this generic letter.
Sincerely, h
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.W A4L Darre l'G'. Er s4nhut, rectnr l
Divisier o' Licensing l
Office of Nuclaar Reactnr Regulatier
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LIST OF RECENTLY ISSUE 0 GENERIC LETTERS l
I l
GENERIC
,t l
LETTER NO.
SUBJECT DATE 84-15 Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability 7/2/84 l
84-16 Adequacy of On-Shift Operating Exper-ience for Applicants 6/27/84 84-17 Annual Meeting to Discuss Recent Develop-l l
ments Regarding Operator Training, Qualifications and Examinations 7/3/84 l
84-18 Filing of Applications for Licens'es and Amendments 7/6/84 i
84-19
. Availability of Supplement 1 o_.NUREG-0933 "A Prioritization of Generic Safety Issues" 8/6/84 i
84-20 Scheduling Guidance for Licensee Submittals of Reloads that Involve Unreviewed Safety Questions 8/20/84 84-21 Long Term Low Power Operation in PWR's 10/16/84 84-22 Not used
_ 84-23 Reactor Vessel Water Level Instrumentation i
in BWRs 10/26/84 84-24 Clarification of Compliance to 10 CFR 50.49 Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants 12/27/84 85-01 Fire Protection Policy Steering Committee Report 1/9/85 85-03 Clarification of Equivalent Control Capacity 1/28/85 For Standby Liquid Control Systems i
e b
.